UPDATED MARCH 2022
We appreciate that you trust us when you provide us with your information. Protection of information is our top priority because we want to keep your trust.
THE TYPES OF DATA WE COLLECT
When you use our Products, Services and websites, we collect the Personal Data that you give us, which includes:
Information that you provide voluntarily
Certain parts of our website, Products or Services may ask you to provide Personal Data voluntarily: e.g., we may ask you to provide your contact
Information that we collect automatically
The Personal Data we may obtain through cookies includes: Unique identifiers, such as IP address, browser type, operating system, the pages you view on the websites, the pages you view immediately before and after you access the websites, and the search terms you enter on the websites, Internet or other electronic network activity information;
In some cases, your Personal Data will be supplemented by information retrieved from public sources, such as online media or employer websites, for the purpose of confirming your current professional position or address.
Personal Data TLINE does not seek to collect
TLINE does not need special categories of personal information (also known as “sensitive personal information or data”), as defined by Mexican Federal Law of Protection of Personal Data in Possession of Individuals or the GDPR and UK GDPR, to provide its Products or Services. TLINE avoids collecting sensitive Personal Data from you through the Services, Products or otherwise. Unless TLINE specifically requests it, please do not provide sensitive Personal Data to TLINE. If you choose to provide TLINE with unsolicited sensitive Personal Data, TLINE will process it only as necessary to establish, exercise or defend legal claims. In the rare circumstances in which TLINE does seek to collect sensitive personal data, TLINE will do so in accordance with data protection laws and/or ask for your consent.
HOW WE USE YOUR DATA AND OUR LEGAL BASIS TO PROCESS YOUR DATA
We use the Personal Data primarily to provide Products (including via targeted advertising), Services and respond to requests we receive from you. We use account-related data provided by customers to us in connection with the purchase, sign-up, use or support of customer account (such as usernames, email address and billing information) to provide you with access to our website, Products or Services, to contact you regarding your use of our Products or Services or to notify you of important changes to our website, Products or Services. Such processing is necessary for the performance of the contract between you and TLINE. When you ask for information about our Products or Services (for example, when you ask us to send you offers or price information), we
will use your contact information to respond to your requests. Such processing is necessary to respond to or implement your request prior to entering into a contract with us.
We also use the Personal Data for communication purposes, including to send you newsletters, promotions, surveys and other product-related information and to maintain our list of contacts. We will send you such information only based on your prior consent, which is given at the time you provide us with the respective Personal Data. In such case, if you do not provide us with your consent to the processing of your Personal Data for communication purposes, we will not send you respective information. You may withdraw your consent to receive such communications at any time. Please note that we will continue to contact you via email to respond to your requests and regarding the provision of our Products or Services.
We use data relating to your use of the website, Products or Services to analyze, administer, support and improve your access to and use of the website, Products or Services, including fraud prevention. Collecting this information enables us to better understand the visitors who come to our website and/or use our Products or Services, where they come from, and what content on our website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our website, Products or Services to our customers and end users. We may also compile, anonymize and/or aggregate your Personal Data and other data and use such anonymized and/or aggregated data for our business purposes, including sharing such data with affiliates and business partners. This aggregate information does not identify you, i.e., it is not considered Personal Data.
We also may use your Personal Data in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law. Additionally, we may anonymize or aggregate your information and use it for other purposes as permitted by applicable law.
OUR BASIS FOR USING YOUR DATA
If you access our Services or use our Products from the European Economic Area or the UK, our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. When processing
Where we rely on legitimate interests to process Personal Data, we will balance our need to process that information with any risks such processing poses to your rights and freedoms.
SHARING AND DISCLOSURE
We do not sell or otherwise make your Personal Data available to third parties, although we may disclose your Personal Data to the following categories of recipients: to our group companies (including those in Switzerland, Bermuda, Cyprus, Germany, Japan, Russia, the United Kingdom, Ukraine, Mexico, Chile, Argentina, Brasil and the United States), third party services providers and partners who provide data processing services to us (e.g., to support the delivery of, provide functionality on, or help to enhance the security of our website and/or products), or who otherwise process Personal Data for purposes that are described in this Privacy Notice or notified to you when we collect your personal information (when they perform services on our behalf, mainly to maintain and support our IT systems).
We may also disclose your Personal Data to third parties including law enforcement bodies, regulatory, government agencies or other third parties in the following circumstances: (a) to undertake the activities listed above; (b) to conform to legal requirements or comply with legal process (including assisting in the investigation of suspected illegal or wrongful activity or to deal with any misuse of the product); (c) to sell, make ready for sale or dispose of our business in whole or in part including to any potential buyer or their advisers.
INTERNATIONAL DATA TRANSFERS
Use of our Products and Services sometimes involves cross-border transfers of Personal Data. TLINE may transfer your Personal Data to the following countries: Switzerland, Bermuda, Cyprus, Germany, Japan, Russia, the United Kingdom, Ukraine, Mexico, Chile, Argentina, Brasil and the United Sates.
For cross-border transfers of Personal Data to jurisdictions not guaranteeing an adequate level of data protection, TLINE uses appropriate safeguards to guarantee that your personal data be protected in accordance with this Privacy Police and applicable data protection laws. These safeguards include implementing the either the European Commission’s or the Information Commissioner’s Office (“ICO’s”) standard contractual clauses (Art. 46 GDPR/ UK GDPR), adapted to satisfy applicable law requirements if necessary, which may be read here and other valid mechanisms for transfers of personal data among our affiliates, data processors or third parties.
MEASURES TO KEEP YOUR DATA SAFE
We maintain reasonable and appropriate technical and organizational security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in light of the risks inherent in processing this information. We regularly review our security policies and procedures to ensure our systems are secure and protected.
We retain Personal Data we collect from you as long as we have an ongoing legitimate business need to do so (e.g., to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). To determine the appropriate retention time for your Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve these purposes through other means, as well as applicable legal requirements.
When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not
possible (e.g., because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.
Within the EU and UK, the data controller (i.e., the person who or entity that determines the purpose and means of processing) for the Personal Data collected pursuant to this Privacy Statement is T-LINE MÉXICO, S.A. DE C.V., Ave. Paseo de la Reforma 404-1102, Col. Juárez, Cuauhtemoc, CDMX, México. Under the GDPR adn UK GDPR you have the following rights in relation to your Personal Data:
Right of access: You have the right to know if and what Personal Data we process about you and may request a copy of that Personal Data (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
Right to rectification: You are entitled to have incorrect or incomplete Personal Data about you corrected or completed. If we have shared your Personal Data with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
Right to erasure: You may ask us to delete your Personal Data. Under some circumstances we might not be able to delete your Personal Data (e.g., in case we are required to keep your Personal Data by law). If we have shared your Personal Data with others, we will inform them about the erasure where possible. If you ask us, where possible and lawful to
do so, we will also inform you with whom we shared your Personal Data so that you can contact them directly.
Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of that Personal Data or object to the processing of it. We will tell you before we lift any restriction on processing. If we have shared your Personal Data with others, we will inform them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so that you can contact them directly.
Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so: if we are relying on a legitimate interest to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or if we are processing your Personal Data for direct marketing purposes. Please note that the limitation or deletion of your Personal Data may mean that we will be unable to provide you our Products or the Services described above.
Right to data portability: You also have the right to receive your Personal Data in a machine-readable format and have the data transferred to another party responsible for data processing.
Rights in relation to automated decision-making and profiling: You have the right to be free from decisions based solely on automated processing of your Personal Data, including profiling, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. To opt out of any received emails or other promotional communication, please unsubscribe by selecting “unsubscribe” at the bottom of a received e-mail or by contacting us as indicated in the “Contact Us”. This will not affect the lawfulness of processing based on your prior consent.
Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
EXERCISING YOUR RIGHTS
You may exercise your rights by contacting us as indicated in the “Contact Us” section below.
COMPLAINTS TO THE REGULATOR (UK ONLY)
You have the right to make a complaint at any time to the ICO, the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns and do our best to resolve such concerns before you approach the ICO so please contact us in the first instance.
California Privacy Notice
This California Privacy Rights Notice (“California Privacy Notice“) explains privacy rights available to residents of the State of California as required by the California Consumer Privacy Act of 2018 (“CCPA”). If this California Privacy Notice and any provision in the rest of our Privacy Statement conflict, then this California Privacy Notice controls for the processing of Personal Information of residents of the State of California. In CCPA, California residents are referred as “consumers” and we refer to them in this California Privacy Notice as “California Consumers” and “Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Consumer or household.
Our website 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 Data”). In particular, we have collected the following categories of Personal Data from Consumers within the last twelve (12) months.
Category Examples Purpose
Identifiers Name, postal address, email address, unique identifier, Internet Protocol address, account name, and similar identifiers. To provide you with information about the Products and Services that you request from us; to provide and deliver our Products and Services; to prevent fraudulent transactions; to maintain the security of the TLINE infrastructure.
information Products or services purchased, obtained, or considered; other purchasing or To analyze the way in which Consumers are accessing and using our Products and Services so that we can perform necessary marketin
consuming histories or tendencies further improve our website, Products and Services.
activity Browsing history; search history; unique personal identifier; online identifier; Internet Protocol address; information on a consumer’s interaction with a website, application, or advertisement To analyze how our Customers and users access and use our website, Products and Services and to improve the consumer experience.
data Physical location or movements To ensure the proper website experience is delivered; to analyze web traffic so as to conduct marketing activities.
In addition to the purposes stated above, we may use or disclose Personal Data obtained from you for one or more of the following business purposes: To fulfill or meet the reason you provided the Personal Data. For example, if you share your name and email address to receive information about our Products or Services, we will use that Personal Data to respond to your inquiry. If you provide your Personal Data to purchase our Products or Services, we will use that information to process your payment and provision the applicable our Products or Services that you purchased. To provide, support, personalize, improve, and develop our Site, your interaction with our website, Products or Services. To provide you with information that you request from us. To create, maintain, customize, and secure your Account or Platform. To prevent transactional fraud. As necessary or appropriate to protect the rights, property or safety of us, our Customers or others. 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 deliver targeted content and relevant offerings, including event registrations, alerts, offers, and ads delivered through our Site and via email (with your consent, where required by law). For testing, research, and analysis of our website, Products or Services. To respond to valid law enforcement requests and as required by applicable law, court order, or governmental regulations. As described to you when collecting your Personal Data or as otherwise set forth in the CCPA.
CCPA offers California Consumers the following key privacy rights: You have the right to request information about categories and specific pieces of Personal Information that we have collected about you (see table above), as well as the categories of sources from which the Personal Information is collected, the purpose for collecting Personal Information and the categories of third parties with whom we share Personal Information. You have the right to request information about our disclosure for business purposes of your Personal Information to third parties. You have the right to request that we delete certain Personal Information that we have collected from you. If we offer a financial incentive or price or service difference in exchange for your Personal Information, we will notify you in advance before collecting your Personal Information for this purpose and explain how you can opt in to the financial incentive or price or service difference. You have the right to opt out of our sale of your Personal Information if and when we determine the purpose and means of processing of your Personal Information. (In CCPA, “sale” means transferring or making available Personal Information to third parties for monetary or other valuable consideration.) Sharing your Personal Information with our service providers is not a sale of your Personal Information because we make sure that our service providers are contractually obligated to use the Personal Information only to provide services to us and not to sell it. Note that TLINE does not sell (within the meaning of CCPA) your Personal Information to third parties and accordingly, we do not provide you with information about how to opt-out of sale of your Personal Information. If this policy changes, we will notify you and provide you with information about how to opt out of sale of your personal data by us. You have the right to not receive discriminatory treatment from us for exercising any of your privacy rights. That is, we cannot treat you differently for exercising any of these rights unless we demonstrate that the value of the Personal Information that you provide to us is reasonably relate to the difference in price or service that we offer.
EXERCISING YOUR RIGHTS
To exercise any of your available rights, please submit a request to us by: Calling us at [+52 55357079] or Sending an email to firstname.lastname@example.org with the subject line “California Privacy Rights Request.”
TLINE does not intend to and not knowingly collect Personal Data from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Data to TLINE through this website, please contact us at email@example.com and we will endeavor to delete that information from our databases.
COOKIES AND SIMILAR TRACKING TECHNOLOGY
LINKS TO OTHER WEBSITES AND SERVICES
HOW TO CONTACT US
If you have any questions about how we process your personal data, please feel free to contact our Data Protection Officer at firstname.lastname@example.org