Privacy Policy

Intent

Protecting the privacy and confidentiality of personal and client information is an important aspect of the way TMG (“Company”)  conducts its business. Collecting, using, and disclosing personal and client information/data appropriately, responsibly, and ethically is fundamental to the company’s daily operations.

The company strives to protect and respect the personal information of its customers, employees, business partners, and so on in accordance with all applicable statutory requirements. This extends to all Processing of Personal Data by Staff, (Sub) Processors, agents or representatives- whether online or offline or by manual or automatic means. All employees must abide by the procedures and practices set out below while handling Personal Data.

This Privacy Policy explains what Personal Data the Company collects about you and why, what we do with that information, how we share it, and how we handle the information you share in order for us to service your business needs. For the purposes of this Privacy Policy, “Personal Data” is any factual or subjective identifying information about an individual or group of individuals. This can include name, date of birth, address, income, e-mail address, social insurance number, gender, evaluations, and so forth. Please read the following carefully to understand our practices regarding Personal Data, including Personal Data of visitors to our Website and our customers (“Customers”).

Scope

This policy refers to all parties (employees, contractors,  job candidates, customers, suppliers etc.) who provide any amount of information to us.

Guidelines

This policy outlines the company’s commitment to privacy and establishes the methods by which privacy is ensured. This policy applies to all employee and customer Personal Data in the company’s care, custody, and control.

Business information is confidential information related to a specific business that is not readily available to the public, such as names of executive officers, business registration numbers, proprietary information, and financial status. Business information is treated and handled with the same level of confidentiality, privacy, and respect as Personal Data.

Consent occurs and is considered obtained by TMG when an individual provides express consent orally, in writing, or through an applicable online action. Before being asked to provide consent, individuals will be provided with the reasons their Personal Data is being collected, how it will be used and stored, and any disclosure or possible disclosure of the information.

Implied consent is granted by the individual where consent may reasonably be inferred from the action or inaction of the individual. Where possible, this should always be followed up by a TMG representative to obtain express consent.

Information you provide us

TMG collects and uses personal data solely for the purpose of conducting business and developing an understanding of its customers. The Company hereby asserts that personal data may only be used for the following purposes:

  • To provide services to our Clients/Customers
  • Recruitment and selection
  • To purchase products and services
  • To respond to inquiries through our website and communicate with registrants
  • Corresponding with us by phone, e-mail or otherwise

 

How we use the information we collect

We collect the Personal Data described above in order to provide our Services to our Customers, to market our products and services, to improve our website and to recruit staff. 

 

We will use the information we collect in the following ways:

 

Customers:

  • To fulfill our obligations arising from our contract with you
  • To liaise with you about projects that we are undertaking with you
  • To deliver information about our services or products
  • To ensure payment of our invoices

 

Website Users:

  • To administer and improve our Website and for internal operations, including data analysis, testing, research and statistical and survey purposes.
  • As a part of our efforts to keep our Website safe and secure
  • To measure or understand the effectiveness of advertising we serve to you and others
  • To make suggestions and recommendations to you and other users of our Website about services that may interest you or them

Job Applicants:

  • To assess your education/work experience and skills against open job positions within our company

 

Who do we share your information with

 

We may share your personal data with our selected business partners, suppliers, and sub-contractors for the performance of any contract we enter into with them or you. For example, these business partners may include our web hosting provider or our IT services providers. We use several subprocessors and service providers to assist us in providing the Website and Services and in addition, we may disclose your Personal Data to third parties:

 

  • In the event that we sell or buy any business or assets, in which case we may need to disclose your Personal Data to the prospective seller or buyer of such business or assets.
  • If we or substantially all of our assets are acquired by a third party, in which case information held by us about our Customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your information in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements: or to protect our rights, property or safety, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk management.

 

Data Storage

Data Locality

Given we are a global team, the data that we collect from you may be transferred to, and stored in the United States of America, Canada, South America and parts of Europe including countries within and outside the European Economic Area (“EEA”) and for which there is an adequacy decision relating to the safeguards for personal data from the European Commission. For information about the adequate security safeguards that have been put in place for data you can reach out to Paul Giesler (Data Protection Officer) at pgiesler@tmg.io 

 

Data Retention

The company will retain personal data only for the duration it is needed for conducting its business and ensuring statutory compliance. Once personal data is no longer required, it will be destroyed promptly, safely, and securely. However, certain laws may require that certain personal data be kept for a specified amount of time. Where this is the case, the law will supersede this policy.

 

Your data rights

You have the following rights in respect of your Personal Data:

  • The right to access the Personal Data we hold about you.
  • The right to require us to rectify any inaccurate Personal Data about you
  • The right to ask us to erase your Personal Data in certain circumstances.

 

As a Customer of the Company, you have the following rights:

  • The right to have us erase any Personal Data we hold about you in circumstances such as where it is no longer necessary for us to hold Personal Data or, in some circumstances, if you have withdrawn your consent to the processing.
  • The right to object to us processing Personal Data about you such as processing for profiling or direct marketing purposes.
  • The right to ask us to provide your Personal Data to you in a portable format or, where technically feasible, for us to port that Personal Data to another provider provided it does not result in a disclosure of Personal Data relating to other people.
  • The right to request a restriction of the processing of your Personal Data.
  • The right to address a challenge concerning the Personal Data handling policies and practices of the Company.

 

The Company seeks to adhere to globally-accepted Data Protection Laws and Regulations that govern the Processing of Personal Data.

 

Policy Statements

TMG assumes full accountability for the Personal Data within its possession and control. The company has appointed Tara Shelley (VP of People and Culture) and Paul Giesler (SVP of Engineering and Infrastructure) as the custodian of all privacy matters and legal compliance with privacy laws.

In the course of conducting its business, the company may have to obtain Personal Data directly from the individual to whom the information belongs. Individuals whose Personal Data is being collected are at all times entitled to know how the company uses their Personal Data and that the use of any Personal Data collected is limited to only what is needed for those stated purposes. If necessary, TMG will obtain individual consent if Personal Data is to be used for any other purpose.

The company will not use that information without the consent of the individual.

Under no circumstances will the company sell, distribute, or otherwise disclose Personal Data, including personal contact information or employee lists, to third parties, unless required to do so by law. This may include consultants, suppliers, or business partners of the company, but only with the understanding that these parties obey and abide by this policy, to the extent necessary for fulfilling their own business duties and day-to-day operations.

The company will take every reasonable precaution to protect Personal Data with appropriate security measures, physical safeguards, and electronic precautions. The company maintains Personal Data through electronic files. Where required by legislation, disaster recovery or business continuity policies, older records may be stored in a secure, offsite location.

TMG will ensure:

  • Access to Personal Data is authorized only for the employees and other agents of the company who require the information to perform their job duties, and to those otherwise authorized by law;
  • The company’s computer network systems and databases are secured by complex passwords and firewalls to which only authorized individuals may access;
  • Active physical files are kept in locked filing cabinets;
  • Routers and servers connected to the Internet are protected by a firewall, and are further protected against virus attacks or “snooping” by sufficient software solutions;
  • Personal Data is not transferred to employees, volunteers, summer students, or any other person in the company unless authorized.

The TMG website will include our privacy policy and disclose our Personal Data practices. Individuals adding data to the website will be notified about the following:

  • Personally identifiable information about the individual that is collected from the website or through affiliate sites;
  • Information about the organization collecting the data;
  • How the data will be used;
  • To whom the data may or may not be disclosed;
  • What options are available to the individual regarding the collection, use, and disclosure of Personal Data;
  • The information technology security procedures in place that protect against the destruction, loss, theft, alteration, or misuse of Personal Data under the company’s possession and control; and
  • How the individual may access and correct any inaccuracies in their Personal Data.

In addition, TMG will explain that the company may share compiled demographic information with its business partners or advertisers, but no Personal Data that can identify any individual person will be disclosed. While IP addresses will be logged in order to administer the site, track visitor movement, and gather demographic information, but these IP addresses will not be linked to any personally identifiable information. Any registration or order form asking site visitors to enter personal or financial information will be protected by SSL encryption. Site visitors may opt out of having their Personal Data used at the point where the information is gathered.

In most instances, TMG will grant individuals access to Personal Data in the care, custody, and control of the company upon presentation of a written request and satisfactory identification. If an individual finds errors of fact with their Personal Data, they should notify the company as soon as possible to make the appropriate corrections.

If the company denies an individual’s request for access to their Personal Data, the company will advise in writing of the reason for such a refusal. The individual may then challenge the decision.

TMG may use Personal Data without the individual’s consent under particular circumstances. These situations include, but are not limited to:

  • The collection is clearly in the interests of the individual and consent cannot be obtained in a timely way;
  • The Personal Data was produced by the individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was provided;
  • The collection is made for the purpose of making a disclosure required by law; or
  • Any other reason as defined in applicable legislation

Any questions or concerns regarding this policy can be addressed by contacting TMG at hr@techmatesgroup.com The company will investigate and respond to concerns about any aspect of the handling of Personal Data. This organization will address concerns to the best of its abilities.

 

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