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Website Privacy Policy

 

LAST UPDATE: May 18, 2018

TLS Corp. and its affiliates (“Telos Alliance”, “we”, “our”, and “us”) respect your concerns about privacy and personal data protection and value our relationship with you. This Website Privacy Policy (the “Policy”) applies solely to personal information collected through the Telos Alliance website, online services, and web pages that post, specifically reference, and incorporate this Policy (all of the foregoing, collectively, the “Site”), whether accessed via computer, mobile device or other device (collectively, “Device”).

This Policy describes the types of personal information we collect through the Site and how that personal information may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices at this Site. Please read this Policy carefully, because by accessing and using this Site you are acknowledging that you understand and agree to the terms of this Policy. In addition, please review our Terms of Use, which governs your use of this Site.

CONSENT

Consent to Data Collection and Processing

You hereby agree with and consent to the collection and processing of your personal information as described in this Policy.

Consent to International Data Transfers

Your personal information may be collected, processed and stored by Telos Alliance or its service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. You hereby agree with and consent to the transfer of your personal data to the United States and other countries where Telos Alliance operates.

Withdrawal of Consent

You have the right, at any time, to withdraw your consent to Telos Alliance’s collection and processing of your information, or to the transfer of your personal data to the United States and other countries where Telos Alliance operates. You may withdraw your consent by emailing Telos Alliance at privacy@telosalliance.com.

COLLECTION AND USE OF PERSONAL INFORMATION

As you interact with Telos Alliance, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about you or your Telos Alliance products as further described below.

You may provide us with information about you or your Telos Alliance products through a number of sources: Telos Alliance websites, applications, product and related events, surveys, social media platforms, sweepstakes entries, and through our customer contact centers. We may also receive information about you through Telos Alliance product sales records provided by a distributor and we may obtain, with your consent, data obtained from your Telos Alliance product.

The types of information that Telos Alliance collects about you may include, but are not limited to:

  • Contact information (such as name, address, city, state and ZIP code, age or date of birth, occupation, social security number, email address and telephone number)
  • Payment information (such as your bank account information, credit card number, debit card number, bank or investor account, CVV code, expiration date, and payment history)
  • Information related to your creditworthiness, assets, income, or liabilities
  • Information about your Telos Alliance product
  • Information about your connected Devices and how you interact with our Site (such as IP address, browser type, unique device identifier, cookie data, and associated identifying and usage information)
  • Demographic information (such as gender, date of birth, marital status, and household composition)
  • Marketing profile information (such as when you plan to purchase a Telos Alliance product)
  • Photographs and videos such as those that you may submit for contests, sweepstakes and social sharing
  • Relationships you have with Telos Alliance in addition to the purchase and servicing of your Telos Alliance product (such as through a rewards card, etc.)
  • Incentive eligibility verification information (such as college name, branch of service, or credit union name for Telos Alliance product purchase programs)
  • Social Security Number (in limited circumstances Telos Alliance may collect SSN, for example if you win a sweepstakes or receive compensation that must be reported for government tax purposes)
  • Investor information (name, address, phone number, and email address)
  • The kind of Telos Alliance product you purchased
  • The kind of service provided to you

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social media, or other electronic messages, or via our websites and applications.

Personal Information You Provide

The privacy and security of the personal information that Telos Alliance collects from you is a priority for Telos Alliance.

  • When you visit this Site you may choose to provide personal information that could reasonably be used to contact you or to identify you personally including, but not limited to: your name, address, telephone number, company, and email address.
  • If you choose to make a payment on the Site, Telos Alliance may ask you to provide your name, mailing address, telephone number and email address, as well as certain financial information (e.g., credit card number) for the purposes of payment and processing of any order.
  • You may choose to receive certain communications from Telos Alliance via your email address upon interaction with the Site. From time to time Telos Alliance may include surveys, information requests, or other features on the Site which ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by Telos Alliance to allow you to participate in the particular feature being offered. Telos Alliance may also retain any information you provide in order to send you information about Telos Alliance’ products and services that may be of interest to you. Telos Alliance will provide you with the opportunity to opt-out of receiving such communications. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.

You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to Telos Alliance at this Site, you hereby consent to Telos Alliance’s collection, use and disclosure of such personal information.

We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.

Passive Information Collection and Use

As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We passively collect and use information in a variety of ways, including:

  • Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access this Site through a mobile Device.
  • Cookies: Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to collect information such as browser type, time spent on this Site, pages visited, and language preferences. We and our service providers use the information for security purposes, to facilitate navigation, and display information more effectively. In addition, we use cookies to gather statistical information about Site usage in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. If you set your browser to reject cookies, part of the Site may not work for you.

  • Pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.
  • IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.
  • Device Information: We may collect information about your Device, such as a unique device identifier.
  • Do Not Track Requests: Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.

We permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we use advertising services provided by third-party ad partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt-outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices.

We utilize Google Analytics on the Site. Google Analytics is a website analysis service provided by Google, Inc. (“Google”). Google utilizes the data collected to track and examine the use of this Site, to prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. For more information on Google’s Privacy Policy go to https://www.google.com/intl/en/policies/privacy/. Users can opt-out of Google Analytics tracking at https://tools/google.com/dlpage/gaoptout/.

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

How We Use and Disclose Information

We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) submit payment or credit card information, and (2) submit your name and e-mail address to receive product updates and marketing information. We also use and transfer personal information from or about you:

  • to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail;
  • to send you important information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information;
  • for our business purposes, such as marketing new products and services, data analysis, audits, developing new products or services, operating or enhancing our Site, improving our products and services, identifying Site usage trends, providing products and services, maintaining customer relationships, improving the quality, safety, and security of our products and services, administering your account(s), troubleshooting, supporting electronic signature, customizing and improving communication content, evaluating product performance, providing customer support and product support, warranty administration, and determining the effectiveness of our Site;
  • to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services;
  • to verify your information and authenticate payments and process orders, such as disclosing certain financial and other information you provide to Telos Alliance to third parties that provide credit reporting, payment or order fulfillment services;
  • to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
  • when we otherwise have your consent.

In addition, we use and disclose personal information collected through this Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We also use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.

Use of Information for Marketing Purposes

Telos Alliance and our affiliates may send you regular promotional communications about our products, services, events and promotions. Such promotional materials may use any of the Telos Alliance brands and may be sent to you via different channels, such as: email, phone, SMS text messages, postal mailings, and third party social networks.

In order to provide you with the best personalized experience, sometimes these communications may be tailored to your preferences (for example, as you indicate these to us, as we may have inferred from your Site visits, or based on the links you click in our emails). When required by applicable law, we will obtain your consent before starting these activities. In addition, you may withdraw your consent (opt-out) at any time.

In particular, you can opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email. You can also contact us using the contact details provided below to opt-out from receiving marketing-related communications.

Please note that even if you opt-out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our products, order confirmations, notifications about your account activities, and other important notices.

THIRD PARTY SITES AND SERVICES

This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.

CHOICES AND ACCESS

We give you choices regarding our use and disclosure of your personal information. Telos Alliance provides you with the opportunity to receive information by email, regular mail or telephone calls from Telos Alliance, or third parties which may be of interest to you, including information relating to new products and services offered on the Site by Telos Alliance, or other third parties. If you do not want to receive any information by email, regular mail or telephone calls, you may opt-out of further communications provided by Telos Alliance at any time by: (i) sending Telos Alliance an email at privacy@telosalliance.com; or (ii) writing to Telos Alliance at 1241 Superior Avenue, Cleveland, OH 44114, Attention: Privacy. Please note that Telos Alliance can only comply with requests relating to email, regular mail or telephone communications provided by Telos Alliance. If you no longer wish to receive further information by email, regular mail or telephone from any third party, you will need to contact such third party directly to opt-out of further communications being provided to you. We will seek to comply with your request(s) as soon as reasonably practicable.

If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us. We will try to comply with your request as soon as reasonably practicable.

ACCURACY

It is your responsibility to provide Telos Alliance with accurate personal information. Except as otherwise set forth in this Policy, Telos Alliance shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, Telos Alliance shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.

YOUR RIGHTS OVER YOUR INFORMATION

By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. You can also ask for it to be erased and you can ask for us to give you a copy of the information. You can also ask us to stop using your information and limit how we use your information.

Your California Privacy Rights

Under California’s “Shine the Light Law”, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.

 

To obtain this information on behalf of Telos Alliance, please send an email message to privacy@telosalliance.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please be aware that not all information is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
 

RETENTION PERIOD

We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.

SECURITY

Telos Alliance has implemented security measures designed to protect personal information provided by you against unauthorized access and use. Telos Alliance also uses commercially reasonable efforts to establish secure connections with your web browser for any transactions conducted online using a credit card or other financial information you may provide to Telos Alliance. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the CONTACTING US section below.

MINORS

We do not intentionally collect information from individuals under the age of 13. The Site is not directed to individuals under the age of 13 and we request that these individuals not provide personal information through this Site.

INTERNATIONAL USERS

This Policy is meant to guide Telos Alliance with respect to personal information collected from or about you at this Site. While this Policy applies to personal information generally, the local laws, rules and regulations of jurisdictions that are applicable to Telos Alliance (“Local Laws”) may require standards which are stricter than this Policy and, in such event, Telos Alliance will comply with applicable Local Laws. Specific privacy policies may be adopted to address the specific privacy requirements of particular jurisdictions. All the information you provide may be transferred or accessed by entities around the world as described in this Policy. Your personal information may be stored and processed in any country where we have facilities or service providers, and by using our Site or by providing consent to us (where required by law), you specifically acknowledge and agree to the transfer of information to countries outside of your country of residence, including to the United States, which may provide for different data protection rules, and a lower standard of required protection, than in your country. Irrespective of which country your personal data is transferred, we would only share your personal data under a ‘need to know’ basis. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by organizational, technical, contractual and/or other lawful means.

EU

In the European Economic Area and Switzerland (“EU”), “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you. The legal basis’ for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. Personal Data regarding individuals who reside in a member state of the EU is controlled by TLS Corp., SIA Axia Broadcast Technologies, or Telos Alliance GmbH (EU Subsidiaries of Telos Alliance) and processed on its behalf by Telos Alliance. Telos Alliance uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland. To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, withdrawing your consent to Telos Alliance’s use or disclosure of your Personal Data will mean that you cannot take advantage of certain Telos Alliance products or services.

UPDATES TO THIS PRIVACY POLICY

We may change this Policy. Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. Your use of this Site following these changes means that you accept the revised Policy.

COMPLIANCE

Telos Alliance will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.

If you believe that your personal information has been processed or disclosed in violation of this Policy, Telos Alliance encourages you to raise any concerns using the contact information provided in this Policy. Telos Alliance will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

YOUR RIGHT TO COMPLAIN AND CONTACT INFORMATION

All individuals whose personal data has been collected or processed by Telos Alliance are encouraged to inform of material privacy issues that can be perceived as violations of their rights.

If you have a complaint as to our use of your information, you may file a complaint with us, the GDPR supervisory authority (if applicable), any other governmental agency, and/or a judicial body. All complaints should contain the following: date; first and last name; contact address; email address; relevant identification you wish to provide; and the object of your complaint.

If you have a compliant or any questions about this Policy, please contact Telos Alliance directly:

  • In writing by sending an email to privacy@telosalliance.com;
  • In writing by sending a letter to 1241 Superior Avenue, Cleveland, OH 44114; or
  • Orally by directly contacting +1 216-241-7225.
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