WEBSITE PRIVACY NOTICE It is important that you understand how TGF collects, stores, shares and uses information from and about you. We adhere to this notice, which applies generally to all websites operated by TGF (“Website”), in respect of our collection, use and disclosure of personal and non-personal information collected through the Website or in the course of our business activities conducted elsewhere. Should another site that is controlled, operated, or administered by TGF provide privacy information which is inconsistent with this notice, this notice shall govern and to the extent necessitated by applicable law. This notice does not apply to the information collected, stored, shared, or distributed by third-party sites. This notice may be updated from time to time. Please read this notice carefully. By visiting our Website, you acknowledge the practices described in this notice, subject to those circumstances where your specific consent is requested. For the purposes of applicable data protection law, TGF is the controller of any personal information collected from you on the Website or otherwise for the purpose of conducting or developing our business with you.
Information We Collect Automatically
When you visit our Website, our server automatically collects certain browser or device generated information, including but not limited to:
- your domain
- your IP address
- your date, time and duration of your visit
- your browser type
- your operating system
- your page visits (records of your access)
- information from third parties
- other information about your computer or device
- Internet traffic
We do not use this automatically collected information to try to identify you, and we do not associate it with the information you provide voluntarily, as detailed below. Information You Provide In order to access or use certain portions of the Website or enjoy the full functionality of the Website, or otherwise in conducting business with us or seeking to conduct business with us, you may be prompted to provide certain personal information to us in the following ways:
- by filling in forms (for example, a ‘Contact Us’ form), on our Website or at a trade show or anywhere else we conduct business
- by downloading documentation from our Website
- by subscribing to newsletters or other communications
- by corresponding with us by phone, e-mail or otherwise using our contact details
- by applying for a job, work placement or internship (over our recruitment platform), in relation to which you should also refer to the specific privacy notices made available to you during the recruitment process
Typically, the personal information you give us may include name, business affiliation, address (home, business, billing, or delivery), telephone number, and email address, and any personal details required to resolve any enquiries or complaints as allowed by applicable law. This information may be required to enter into a contract with you (such as in anticipation of [an employment contract] or a purchase agreement) and failure to provide any information may result in our inability to provide requested services or products, [or consider your application for employment]. We may also obtain personal information about you from third parties that collect your information on our behalf. Cookies In order to improve the functionality and content of the Website and your overall experience, TGF has designed the Website to use certain technologies, including cookies, to track access to and use of the Website or gather certain personal information. A cookie is a small file that can be placed on your device’s hard drive or on a website server. We use cookies to obtain some of the automatically collected information described above. Most browsers automatically collect cookies, but you do not have to accept a cookie, and you can in fact modify your browser so that it will not accept cookies. If you elect to not allow these technologies to work in conjunction with the Website, you can change your web browser settings, or you can elect to discontinue accessing and using the Website. If you adjust your web browser settings to reduce the interaction of these technologies with the Website, some portions of the Website, its content, or its functionality may be limited. For more information about cookies including how to set your internet browser to reject cookies please go to www.allaboutcookies.org.
TGF is not responsible for third-parties’ use of cookies or other tracking and gathering technologies resulting from your access or use of third-party content or sites, even if such third-party content or sites are linked to the Website.
By continuing to use our Website [following display of our pop-up cookie notification banner], you agree to our use of cookies.
Different types of cookies are used for different purposes on our Website, these are known as: strictly necessary cookies, performance cookies, and functionality cookies. Some cookies may be provided by an external third party to provide additional functionality to our Website and these are included below.
Strictly necessary cookies
These are cookies that allow TGF to recognize your computer or device and your preferences when using the Website and are this essential to fulfill an action requested by you, such as identifying you as being logged in. If you prevent these cookies by adjusting your browser settings we cannot guarantee how our Website will perform during your visit.
Performance cookies
These are cookies used to improve our Website, for example for analytics that let us see how our Website is being used and where to make improvements. These cookies are used to collect information about how visitors use our Website. The information is collected in an anonymous form and includes the number of visitors, where visitors have come from to reach the Websites and the pages they visited.
Functionality cookies
These cookies facilitate your efficient access to and use of the Website and enhance the performance and functionality of our Website, often as a result of something you’re doing as a user. For instance, to give you better access to and use of content and functionality on the Website, we may personalize our content for you or remember your preferences or advertise content that is more relevant to you.
Managing and Deleting Cookies
If you want to manage cookies, you can do so from your browser. You can find out how to do this by going to the help menu in your browser. Please see www.allaboutcookies.org for further information.
Use of Personal Information
The following is an overview of our purposes for using your personal information. Please remember that additional details on how we process your personal information may be provided to you in a separate notice or contract.
All processing (i.e. use) of your personal information is justified by a “condition” for processing. In addition, processing of sensitive personal information (such as health or racial information provided for a recruitment application) is always specifically justified. In the majority of cases, processing will be justified on the basis that:
- the processing is necessary to perform a contract with you or take steps to enter into a contract at your request
- the processing is necessary for us to comply with a relevant legal obligation
- the processing is in our legitimate interests, subject to your interests and fundamental rights, and notably our legitimate interest in using supplier, customer and Website user data to conduct and develop our business activities with them and with others
- you have consented to the processing
We use the personal information we collect to:
- conduct and develop our business with you and with others
- process, evaluate and complete certain transactions involving the Website, and more generally transactions involving TGF products and services
- operate, evaluate, maintain, improve and develop the Website, and our products and services generally
- fulfil the purpose for which you provided your personal information
- customize our Website to users’ needs
- engage you about events, promotions, the Website and TGF’s products and services
- provide you with documentation or communications which you have requested
- correspond with users to resolve their queries or complaints
- support and manage a recruitment, work placement or internship process, including considering applications and making offers
- provide you with any services or products you request
- send you marketing communications, where it is lawful for us to do so
- protect and ensure safety of the Website, TGF confidential and proprietary information, and TGF employees
- monitor and analyze trends, access to, and use of the Website for advertising and marketing
- manage, protect against and investigate fraud, risk exposure, claims and other liabilities, including but not limited to violation of our terms and conditions, contract terms or laws or regulations
TGF will not sell or rent your personal information to third parties.
Disclosure of Personal Information
We are part of the global TGF group, and from time to time it will be necessary to share your information with our affiliated businesses. We may also appoint third party service providers (who will operate under our instructions) to assist us in providing information, products or services to you, in conducting and managing our business, or in managing and improving the Website. TGF may share your personal information with these affiliates and third parties for any of the following purposes:
- to perform services that the third parties have been engaged by TGF to perform on TGF’s behalf, subject to the obligations TGF assumes under this notice or the appropriate contractual restrictions and security measures
- if required to do so by law, a legal process, legal authority, or other governmental entity having authority to make the request
- if TGF believes it is reasonably necessary to prevent harm or loss, or it believes that the disclosure will further an investigation of suspected or actual illegal activities
TGF reserves the right to share any information that you provide which is not deemed personal information.
You acknowledge that the Website is controlled, operated, and administered by WIS from its offices in the United States, or hosted on servers located globally, but managed by TGF. TGF is a global company and, as a result, WIS may transfer personal information collected on the Website or in the course of conducting business with you and others to other jurisdictions in which TGF operates. If your personal information is transferred outside the EEA to other TGF group companies or to third party service providers, we will take steps to ensure that your information receives the same level of protection as if it remained within the EEA, including by entering into data transfer agreements, using the European Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield. For transfers to other WIS group companies in the United States (a country that has not received a decision from the EEA Commission determining that the United States provides adequate protection to personal information), we have put in place European Commission approved Standard Contractual Clauses, which protect personal information transferred between WIS entities. You have a right to obtain details of the mechanism under which your information is transferred outside of the EEA by contacting the Data Protection Manager. We may share your personal information with third parties in connection with potential or actual sale of our company or any of our assets, or those of any affiliated company, in which case personal information held by us about our users may be one of the transferred assets. We will also respond to requests for information where required by to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us.
Children
The Website is not for use by children under the age of 16 years and TGF does not knowingly collect, store, share or use the personal information of children under 16 years. If you are under the age of 16 years, please do not provide any personal information, even if prompted by the Website to do so. If you are under the age of 16 years and you have provided personal information, please ask your parent(s) or guardian(s) to notify TGF and TGF will delete all such personal information.
Marketing SMS & emails
Where lawful to do so, and subject to your consent where required, we may communicate with you by SMS and email to tell you about our products and services. If you wish to opt-out of receiving marketing communications, please use the ‘unsubscribe’ link provided in our emails or text the STOP number in our SMS, or otherwise contact us directly and we will stop sending you communications.
Security
TGFstrives to safeguard and protect your personal information from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss, and TGF utilizes and maintains certain reasonable processes, systems, and technologies to do so. However, you acknowledge that no transmission over the Internet is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained by TGF are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control.
Retention of your Information
We apply a general rule of keeping personal information only for as long as required to fulfill the purposes for which it was collected, which will include the duration of the applicable statute of limitations. However, in some circumstances we may retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by law, a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. In specific circumstances we may also retain your personal information for longer periods of time corresponding to a statute of limitation so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
External Links
The Website may contain links to third party sites. Since TGF does not control nor is responsible for the privacy practices of those websites, we encourage you to review the privacy policies of these third-party sites. This notice applies solely to personal information collected by our Websites or in the course of our business activities.
Your rights
Subject to applicable law, you may have some or all of the following rights in respect of your personal information:
- to obtain a copy of your personal information together with information about how and on what basis that personal information is processed
- to rectify inaccurate personal information (including the right to have incomplete personal information completed)
- to erase your personal information (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed)
- to restrict processing of your personal information where:
- the accuracy of the personal information is contested
- the processing is unlawful but you object to the erasure of the personal information
- we no longer require the personal information, but it is still required for the establishment, exercise or defense of a legal claim
- you have objected to processing on the basis of our legitimate interests
- to port your data in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you
- to withdraw your consent to our processing of your personal information (where that processing is based on your consent)
- to object to decisions which are based solely on automated processing or profiling
- to obtain or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organization
In addition to the above rights, you have the right to object to any processing of your information which we have justified on the basis of a legitimate interest, including profiling (as opposed to your consent, or to perform a contract with you). You also have the right to object to any processing of your information for direct marketing purposes, including profiling for marketing purposes.
You also have the right to lodge a complaint with your local supervisory authority for data protection. In relation to all of these rights, please contact us using the details given below. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. We will endeavor to respond to your request within all applicable timeframes.
Contact information
If you have any questions in relation to this notice or you wish to exercise any of your rights, please contact us.
REVISION
This Website Privacy Notice was last revised on October 20, 2023.