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2. GENERAL DESCRIPTION OF HOW TB PROTECTS YOUR PERSONAL DATA
It is of great importance to TB, your right to privacy, and the protection of your personal data. We want you to trust that your personal data is secure, and it is in good hands when you deal with TB.
2.1. Which categories of personal data do we collect and how do we process such personal data?
If we learn that any information, we collect has been provided by a child under the age of 13, we will promptly delete that information.
Below is also a chart describing the categories of personal data we collect:
In addition, for recruitment/employment and vendor selection purposes, TB may process the personal information set out in the below table.
2.2. For which purposes and on which legal basis do we use your personal data?
TB uses your personal data only where required for specific purposes. Please view the table below for (i) a list of the purposes for which TB uses your personal data and (ii) an overview of the legal basis for each such purpose.
Legitimate interest means that TB has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy internal reviews and (iv) the rights you have in relation to the processing activity.
We will process your personal information for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws. To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to one of our privacy policies, doing so will be considered as providing your consent to process your personal information, only where such consent is required by mandatory law.
We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.
2.3. Will we share your personal data with third parties?
We may transfer personal data to our service providers and professional advisors, public and governmental authorities, TB companies/affiliates or third parties in connection with TB’s operation of its business, including any (potential) corporate or commercial transaction. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and TB’s internal policies. TB may also transfer your personal data to any of its global affiliates/partners in furtherance of any visits to our TB locations.
For example, we may disclose personal information to third parties for other business purposes as follows:
Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.
2.4. What about sensitive data?
We do not generally seek to collect sensitive data (as defined in the second below) (also known as special categories within the EEA). In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.
The term "sensitive data" refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
2.5. What about data security?
We maintain organizational, physical, and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal data and the processing we undertake.
2.6. Where will your personal data be processed?
As a global organization with offices and operations throughout the world, personal data we collect may be transferred or be accessible internationally throughout TB's global business and between its entities and affiliates.
Any such transfers throughout TB’s global business take place in accordance with applicable data privacy laws.
2.7. What are the sources we get your personal information from?
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), TB’s actual and potential employees, contractors, partners, investors, members of board of directors, shareholders, TB’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, public authorities, public websites and social media, previous employers, educational institutions, suppliers and vendors (including third party data providers).
2.8. How long will your personal data be retained by us?
We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:
2.9. Which rights do you have with respect to the processing of your personal data?
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to TB first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against TB with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).
3. HOW DO WE USE PERSONAL DATA WHEN YOU VISIT TB’S WEBSITE?
In addition to the information set out above, this section describes how we use personal data when you visit TB’s website:
3.1. Which personal data do we gather?
TB collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up as a user, register as an investor or as an ambassador or provide contact information); and (2) indirectly (for example, through our website's technology).
We may collect and process the following personal data:
3.2. Do we include (links to) websites and programs of third parties?
Our websites may include:
3.3. How do we use personal data that we collect from our websites?
We use personal data for the purposes described in section 2.2 above, as well as to provide you with information you request, process user accounts, create investor and partners profiles.
We also analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it, make it more effective and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.
By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies policy.
4. HOW DO WE USE PERSONAL DATA FOR MARKETING PURPOSES?
In addition to the information set out above, this section describes how we use personal data for marketing purposes:
4.1. Do we send targeted e-mails?
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from TB, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from TB may include additional data privacy information, as required by applicable laws.
4.2. Do we maintain Customer Relationship Management (CRM) databases?
Like most companies, TB uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by TB professionals based on their personal interactions with you.
4.3. Do we combine and analyze personal data?
4.4. Do we share personal data with third parties?
In addition to the third parties mentioned in section 2.3. above, we may share your personal data with marketing agencies and service providers.
4.5. What are your rights regarding marketing communications?
You can exercise your right to prevent marketing communications to you by not checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you.
You can exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by communicating to the link indicated in section “6. CONTACT” below. In such cases, we will retain minimum personal data to note that you opted out to avoid contacting you again.
5. HOW DO WE USE PERSONAL DATA FOR PRODUCTION ACTIVITIES?
In addition to the information set out above, this section describes how we use personal data in connection with content creation/production purposes.
Some TB entities are in the business of content production. We may process your personal data for these TV, film, marketing, advertising or other related content creation, production, and distribution activities.
The personal data that we process for production purposes include images and footage of you and may include your location at the time of filming.
If you are a member of public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.
If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.
We may also collect and process special categories of data a such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.
6. CONTACT US
Please send an email to [email protected] if:
LAST UPDATED: March 29, 2021
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