Effective Date: 4/20/2020

TMM Data, Inc ("TMMData" or "we") is committed to privacy and data protection. This Privacy Policy applies to all Personal Data TMMData collects from you (either an individual or a single entity acting on behalf of its authorized individual users), through our interactions with you and through our product; as well as how we use and protect that data. TMMData is the controller of this data.

The Privacy Policy applies to all websites which are run by, or under the control of, TMMData  (collectively, the “Sites”), and our applications, products and services (including the Sites) (collectively, the "Services"). All references to “TMMData”, “the Company”, “we” and “our” include not only TMM Data, Inc, located at 200 Shady Lane, Suite 100, Philipsburg, PA 16866 USA, but also our wholly owned subsidiaries and affiliates, unless expressly stated otherwise.

This Privacy Policy does not apply to the data you input to our Services, or the files generated & managed using our Services (“Your Content”). You act as the controller of Your Content.

This Privacy Policy does not apply to any third-party applications or software that integrate with our Services, or any other third-party products, services or businesses (collectively, “Third Party Services”). Third Party Services are governed by their own privacy policies. We recommend you review the privacy policy governing any Third Party Services before using them.

We may provide additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Listed below are additional disclosures that may be applicable to you.

  • If you are a California resident, please see the additional privacy disclosures below in the Privacy Notice For California Residents.

Any questions or concerns regarding TMMData’s privacy and data protection practices can be directed to our Data Protection Office at dpo@tmmdata.com or by calling +1 (814) 699-8909 or +1-855-554-3282.

Personal Data We Collect

TMMData collects data to provide the Services you request, ease your navigation on our Sites, communicate with you, and improve your experience using our Services. Some of this information is provided by you directly, such as when you create an account on our Sites, request a trial and/ or purchase a Service. Some of the information is collected through your interactions with our Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with TMMData Services running on your device.

We also obtain data from third parties or use third parties to assist us with data collection. For example, we may supplement the data we collect as described in this section by purchasing demographic data from other companies. We also use services from other companies to help us determine a location based on your IP address notably to customize certain services to your location. In addition, we utilize third-party services to collect usage data.

The data we collect depends on the Services and features thereof that you use, and includes the following:

Name and contact data. We collect your first and last name, e-mail address, postal address, phone number, and other similar contact data.

Credentials. We process passwords and related security information used for authentication and account access and information security purposes.

Payment data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number).

Usage data. We collect personalized information about your use of our Services, to better understand uses thereof and identify potential improvements, as well as to send you promotional communications or offers tailored to your use of our Services.

Examples include:

  • Information based on your use of our Services running on your device. This includes the types of files being ingested into the platform, metadata about the data imported (size, shape, type, cardinality, variability, uniqueness, etc), the types and frequency of tools and commands being used, the size and nature of projects, and the frequency and duration of use.
  • Information on the web pages you visit on and off our Sites and the search terms you enter on our Sites.
  • Information regarding the performance of our Services and any problems you may experience while using them. This information enables us to diagnose problems and offer support in resolution.
  • Data about your device and the network you use to connect to our Services, including IP address, device identifiers, and regional and language settings.

Web requests. For our cloud-based Services, we collect information regarding every web request sent to the relevant servers. This information is used to provide support, as well as to assess usage and performance of our Services. The data collected for each request can include such things as timestamps, any exception messages, user agent, IP address, e-mail address, request time and duration, as well as filenames.

Location data. We collect your IP address and infer location such as city or postcode therefrom, when necessary in order to provide you with the Services or to send you promotional communications or for customer relationship management purposes.

Content. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services you use. We will collect and utilize any data files you send to us for troubleshooting and improving our Services so long as you have anonymized, scrubbed, or deleted any personally identifiable information contained therein which you do not want us to collect or utilize. When you contact us, phone conversations or chat sessions with our representatives may be monitored and recorded in order to improve our services, facilitate the processing and resolution of your request or complaint.

Surveys and Studies. We may ask you to participate in a survey or study; and may request information from you. Participation is voluntary, and you have the choice of whether to disclose any requested information.

How We Use Personal Data

TMMData uses information that we collect from customers and visitors for the purposes of:

  • providing our Services;
  • providing ongoing support;
  • communicating with you, including promotional communications and customer relationship management (“CRM”);
  • providing information about other Services;
  • helping us run our company, for example to improve our Services or our security, train staff or perform marketing activities, including CRM;
  • complying with our legal obligations and enforcing our legal rights, including the authorized use of our licenses; and
  • accounting and other administrative purposes.

Examples of the uses of information include:

Providing Services. We use data to carry out your transactions with us and to provide Services to you. Often, this includes personal data such as e-mail, name and address.

  • Customer support. We use data to diagnose and address problems and provide other customer and support services.

Improving Services. We use data to continually improve our Services, including adding new features or capabilities. Data is collected throughout your interactions with our Services that enable us to understand customer usage and tailor future capabilities.

We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of our Sites or utilize specific areas of our Services so that we may improve those Services. We may use your IP address to customize services to your location, such as the language displayed on our Sites.

Our Cookies Policy explains how we use cookies and similar technologies to collect information about the way you use our Services, and how to control them.

Please note that we use IP addresses on a highly restrictive basis to analyze trends, to administer the Sites, and to collect general information for aggregate use.

Service Communications. We use data we collect to deliver and personalize our communications with you. For example, we may contact you by e-mail or other means to notify you of changes in information and updates to our Services or to our Privacy Policy.

Marketing and event communication: We use Personal Data to deliver marketing and event communications to you across various platforms, such as e-mail, direct mail, social media, and online via our Sites. We also may send you invitations to trade shows or trainings relating to our Services that occur nearby you, based on your address.

Third parties may also market to you on our behalf based on your use of their third-party services. For example, some tradeshow organizers may collect precise geo-location (latitude and longitude) data when you grant permission through your mobile device’s system settings. Once you give permission, the tradeshow organizer may use your mobile device’s GPS, Bluetooth or Wi-Fi connections to serve geo-targeted information about TMMData, such as booth location. You should consult and review the relevant third-party privacy statement or policy for information on their data processing practices.

If we send you a marketing e-mail, it will include instructions on how to opt out of receiving these e-mails in the future. We also maintain e-mail preference centers for you to manage your information and marketing preferences. For information about managing e-mail subscriptions and promotional communications, please visit the Your Rights Regarding Personal Data section of this privacy statement. Please remember that even if you opt out of receiving marketing e-mails, we may still send you important Service information related to your accounts and subscriptions.

How We Share Personal Data

It is the policy of TMMData and affiliates to protect Personal Data both online and off-line. Access to Personal Data is restricted to only those employees or agents, contractors or subcontractors of TMMData who have valid reasons to access this information to perform any service you have requested or authorized, or for any other purpose described in this Privacy Policy. The information you provide will not be sold or rented to third parties.

We may provide your Personal Data to:

  • TMMData-controlled affiliates, located in and outside your country, including outside the European Union (in such case, we will use appropriate legal framework to operate data transfers);
  • outsourced service providers who perform functions on our behalf, located inside or outside of the European Union (in such case, we will use appropriate legal framework to operate data transfers). For example, when you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction;
  • our authorized agents and representatives, located inside or outside of the European Union (in such case, we will use appropriate legal framework to operate data transfers), who sell products or provide services on our behalf, such as training service providers or product resellers;
  • anyone expressly authorized by you to receive your Personal Data;
  • anyone to whom we are required by law to disclose Personal Data, upon valid and enforceable request thereof.

Finally, we will access, disclose and preserve Personal Data, including your Content, when we have a good faith belief that doing so is necessary to:

  1. comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
  2. operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks.

Please note that some of our Services may direct you to services of third parties whose privacy practices differ from TMMData’s. If you provide Personal Data to any of those services, your data is governed by their privacy statements or policies. TMM Data, Inc and affiliates are not responsible for the privacy practices of these other sites. Please review the privacy policies for these websites to understand how they process your information.

We require third parties to only use your Personal Data for the specific purpose for which it was given to us and to protect the privacy of your Personal Data. We will only disclose your personal data to third parties who agree to keep your information confidential.

Handling of Personal Data
Security of Personal Data

TMMData is committed to protecting the security of your Personal Data. Depending on the circumstances, we may hold your Personal Data in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect Personal Data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.

These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.

Storage and Transfer of Personal Data

Personal Data collected by TMMData may be stored and processed in your region, in the United States or in any other country where TMMData, its affiliates or contractors maintain facilities, including outside the European Union. We take steps to ensure that the data we collect under this Privacy Policy is processed pursuant to the terms thereof and the requirements of applicable law wherever the data is located.

TMMData also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your Personal Data within TMMData or to third parties in areas outside of your home country. When we do so, we take steps to ensure that Personal Data is processed, secured, and transferred according to applicable law.

If you would like to know more about our data transfer practices, please contact our Data Protection Office at dpo@tmmdata.com.

Retention of Personal Data

TMMData retains Personal Data for as long as necessary to provide the Services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If your Personal Data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.

Your Rights Regarding Your Personal Data

TMMData respects your right to access and control your Personal Data. You have choices about the data we collect. When you are asked to provide Personal Data that is not necessary for the purposes of providing you with our Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features or Services.

We aim to keep all Personal Data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact dpo@tmmdata.com or call +1-(814) 699-8909 or +1-855-554-3282.

Access to Personal Data: In some jurisdictions, you have the right to request access to your Personal Data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under applicable law).

If you are a corporate or institutional user of our Services (which means your employer or institution is a TMMData customer of such Services), please first request access to your Personal Data with your employer or institution. Your employer or institution will then be in touch with us with respect to your request.

Correction and deletion: In some jurisdictions, you have the right to correct or amend your Personal Data if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Data. Please note that such a request could be refused because your Personal Data is required to provide you with the Services you requested, e.g. to deliver a Service or send an invoice to your e-mail address, or that it is required by the applicable law.

Portability: If you reside within the European Union, you have the right to ask for a copy of your Personal Data and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to Personal Data you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.

If you are a corporate or institutional user of our Services (which means your employer or institution is a TMMData customer of such Services), please first request access to your Personal Data with your employer or institution. Your employer or institution will then be in touch with us with respect to your request.

Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about TMMData products, services and events that may be of interest to you, including our newsletter.

E-mail communications you receive from TMMData will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. Please remember that even if you opt out of receiving marketing e-mails, we may still send you important Service information related to your accounts and subscriptions.

You can also request changes to your account by contacting TMMData via e-mail, postal mail, telephone or fax at the appropriate location found at: http://www.tmmdata.com/contact-us/ or by e-mailing unsubscribe@tmmdata.com.

U.S. Children’s Online Privacy Protection Act
OUR SITES ARE NOT INTENDED FOR CHILDREN

The Services are not directed to or intended for use by children under the age of 16. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Sites or Services.

If you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at the address specified below in the “Questions or Complaints Handling” section of this Privacy Policy. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information is located, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the content or information. REMOVAL OF YOUR CONTENT OR INFORMATION FROM THE SITE DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public.

Notice to Users Outside the United States

TMMData is headquartered in the United States. Your use of our Services is governed by United States law. If you are using the website from outside of the United States, your information may be transferred to, stored, and processed in the United States where TMMData’s servers are located. In accordance with and as permitted by applicable law and regulations, we reserve the right to transfer your information, process, and store it outside your country of residence to wherever we or our third-party service providers operate.

Questions or Complaints Handling

We understand that you may have questions or concerns about this Privacy Policy or our privacy practices or may wish to file a complaint. In such case, please contact us in one of the following ways:

TMMData Data Protection Office

E-mail: dpo@tmmdata.com

Phone: +(814) 699-8909 or +1-855-554-3282

Mail: Attention: Data Protection Office

TMM Data, Inc.

200 Shady Lane, Suite 100

Philipsburg, PA 16866 USA

If you are not satisfied with our answer or how TMMData manages your Personal Data, you may also have the right to make a complaint to a data protection regulator. If you reside within the European Union, a list of National Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you reside in Australia, you may obtain information about privacy and lodging a complaint with the Federal Privacy Commissioner (FPC) at www.oaic.gov.au.

Changes To This Privacy Policy

We may update this Privacy Policy based upon evolving laws, regulations and industry standards, or as we may make changes to our business including our Services. We will post changes to our Privacy Policy on this page and encourage you to review our Privacy Policy when you use our Services to stay informed. If we make changes that materially alter your privacy rights, TMMData will provide additional notice, such as via e-mail or through the Sites or other Services. If you disagree with the changes to this Privacy Policy, you should discontinue your use of the Services. You may also request access and control of your Personal Data as outlined in the Your Rights Regarding Personal Data section of this Privacy Policy.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

This section supplements the information contained in this Privacy Policy, and applies solely to visitors, users and others who reside in the State of California (“Consumers” or “You”). We adopt this notice in this section to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this section.

1. INFORMATION WE COLLECT

This Site and Our Services collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, the Site has collected the following categories of personal information from its consumers in the last twelve (12) months. We obtain the categories of personal information listed below as set forth in the methods described in the Personal Data We Collect section above.

Category
Examples
Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

YES

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

 

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
    • Information excluded from the CCPA’s scope, including without limitation: health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
2. USE OF PERSONAL INFORMATION

We may use or disclose the personal information We collect for one or more of the following business purposes:

  • To fulfill or meet the reason You provided the information.
  • To provide, support, personalize, and develop our Site and Services.
  • To create, maintain, customize, and secure Your account with Us.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve Our responses.
  • To personalize Your experience and to deliver content and product and service offerings relevant to Your interests, including offers and ads through Our Site, third-party sites, and via email (with Your consent, where required by law).
  • To help maintain the safety, security, and integrity of Our Site, Services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve Our Site and Services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about Our users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes without providing You notice.

3. SHARING PERSONAL INFORMATION

We may disclose Your personal information to a third party for a business purpose. When We disclose personal information for a business purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share Your personal information with the following categories of third parties:

  • Our affiliates
  • Channel Partners
  • Service providers (including payment processors and partners)
  • Analytics Providers
  • Ad servers

In the preceding twelve (12) months, We have disclosed the following categories of personal information for a business purpose:

  • Identifiers
  • California Customer Records personal information categories
  • Commercial information
  • Internet or other similar network activity
  • Geolocation data
  • Professional or employment-related information

In the preceding twelve (12) months, We have not sold personal information. Under the CCPA, the sale of personal information means “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration.” (Cal. Civ. Code § 1798.140(t)(1)). In the event that We do sell any personal information, We will update this Privacy Policy to list the categories of consumers’ personal information sold, and We will address the sale of such personal information in accordance with the policies set forth below.

4. YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes Your CCPA rights and explains how to exercise those rights.

4.1 Right to Access Specific Information and Data Portability Right

You have the right to request that We disclose certain information to You about Our collection and use of Your personal information over the past twelve (12) months. Once We receive and confirm Your verifiable consumer request, We will disclose to You:

  • The categories of personal information We collected about You.
  • The categories of sources for the personal information We collected about You.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom We share that personal information.
  • The specific pieces of personal information We collected about You (also called a data portability request).
  • If We disclosed Your personal information for a business purpose, the business purpose for which personal information was disclosed, and the personal information categories that each category of recipient obtained.
  • If applicable, (1) the categories of personal information We have sold; (2) the categories of personal information that We sold about the consumer and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each category of third parties to whom the personal information was sold.

4.2 Right to Delete

You have the right to request that We delete any of Your personal information that We collected from You and retained, subject to certain exceptions. Once We receive and confirm Your verifiable consumer request, We will delete (and direct Our service providers to delete) Your personal information from Our records, unless an exception applies.

We may deny Your deletion request if retaining the information is necessary for Us or service provider(s) to:

  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of Our ongoing business relationship with You, or otherwise perform our contract with You.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

4.3 Right to Opt-Out

If You are 16 years of age or older, You have the right to direct Us not to sell Your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by sending Us an e-mail at dpo@tmmdata.com. Once You make an opt-out request, We will wait at least twelve (12) months before asking You to reauthorize personal information sales. However, You may change Your mind and opt back in to personal information sales at any time by sending Us an e-mail at dpo@tmmdata.com. We will only use personal information provided in an opt-out request to review and comply with the request.

4.4 Exercising Your Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Us by either:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable consumer request related to Your personal information. You may also make a verifiable consumer request on behalf of Your minor child.

You may only make such a request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative, and describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.

We cannot respond to Your request or provide You with personal information if We cannot verify Your identity or authority to make the request and confirm the personal information relates to You. Making a verifiable consumer request does not require You to create an account with Us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If We require more time (up to 90 days), We will inform You of the reason and extension period in writing. We will deliver Our written response electronically. Any disclosures We provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response We provide will also explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provide You with a cost estimate before completing Your request.

4.5 Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, We will not:

  • Deny You goods or services.
  • Charge You different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide You a different level or quality of goods or services.
  • Suggest that You may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, We may offer You certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive We offer will reasonably relate to Your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires Your prior opt in consent, which You may revoke at any time.

4.6 Contact Information

If You have any questions or comments about this notice, the ways in which We collect and use Your information described in this Privacy Policy, Your choices and rights regarding such use, or wish to exercise Your rights under California law, please do not hesitate to contact Us at:

Phone: +1-855-554-3282

Website: www.tmmdata.com/privacyrequest

E-mail: dpo@tmmdata.com

Postal Address:

Attention: Data Protection Office

TMM Data, Inc

200 Shady Lane, Suite 100

Philipsburg, PA 16866 USA