Effective as of May 2022
If we intend to use or disclose members’ personal information in a manner materially different from that stated at the time of collection we will notify you by email.
TMT’s Commitment to You
TMT hereby commits to:
- Not collect, maintain, use or share personal information beyond that needed for authorized purposes, or as authorized by you.
- Not sell personal information.
- Not use or disclose information collected (whether personal information or otherwise) for behavioral targeting of advertisements to you.
- Not make material changes to service provider consumer privacy policies without first providing prominent notice to the account holder(s) and allowing them choices before data is used in any manner inconsistent with terms they were initially provided; and not make material changes to other policies or practices governing the use of personal information that are inconsistent with contractual requirements.
- Not knowingly retain personal information beyond the time period required to support the authorized purposes, or as authorized by you.
- Collect, use, share, and retain personal information only for purposes for which we were authorized by you.
- Disclose clearly in contracts or privacy policies, including in a manner easy for you to understand, what types of personal information we collect, if any, and the purposes for which the information we maintain is used or shared with third parties.
- Support access to and correction of personally identifiable information by you.
- Maintain a comprehensive security program that is reasonably designed to protect the security, privacy, confidentiality, and integrity of personal information against risks – such as unauthorized access or use, or unintended or inappropriate disclosure – through the use of administrative, technological, and physical safeguards appropriate to the sensitivity of the information.
- Require that our vendors with whom personal information is shared in order to deliver our services, if any, are obligated to implement these same commitments for the given personal information.
- Allow a successor entity to maintain the personal information, in the case of our merger or acquisition by another entity, provided the successor entity is subject to these same commitments for the previously collected personal information.
“Information” and “personal information” means personally identifiable information (“PII”) that, alone or in combination, is linked or linkable to a specific person that would allow a reasonable person, who does not have personal knowledge of the relevant circumstances, to identify the person with reasonable certainty.
How Are Accounts Created?
We will ask you to create a TMT account to access certain portions of our Software. When you create an account, we will ask for your consent to collect certain types of personal information. Please note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your personal information, the use of the TMT Software may not be possible.
When the primary account belongs to an organization, accounts will be populated in coordination with that organization. Representatives will then be provided login information in a manner specific to that organization and in accordance with organization policy, which may in some cases be through an organization-wide “single sign-on” or by communicating an initial login and password to the representative.
What Information Does TMT Collect About Users?
The information that we collect from logged-in users includes information that you voluntarily provide to us when you sign up for an account and information that is automatically collected when you are logged into the TMT platform.
In every case we also log certain detailed technical information about all users’ interactions with our Software that could be linked with users. This includes the IP addresses that we get when users connect to our Software, information that is sent by web browsers automatically when they connect to our Software (such as the type of web browser, the operating system used and the time zone set on the user’s computer), the timing and frequency of how users interact with different content and different components of our Software.
How We Automatically Collect Information
We the use following methods and tools to collect and track the automatically collected information described above.
We set cookies so that we are able to recognize when someone is connecting to our Software who is currently logged in or who has visited before. A cookie is a data file sent to a browser from a web server and stored on the user’s computer’s hard drive that allows us to recognize that browser when the user returns to our Software. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your browser, or visit http://www.allaboutcookies.org.
Additionally, our video player may store local shared objects, also known as Flash cookies, on users’ computers. Local shared objects cannot be managed in the same way as browser cookies. For information on managing Flash cookies, visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
We (or our third party service providers) may place a tiny image, also known as a pixel tag, in the emails we send, to tell us when you have opened the email. Our team uses this information to improve emails we send to you, and best tailor them to the needs of our organizational clients.
Like most online services, when you use the Software, we automatically collect and store details of how you used our service, such as your activity on the Software, and the frequency and duration of your usage.
By using our Software you agree to our use of these information collection technologies.
What Information Can Other Users See?
When the primary account belongs to an organization, the account administrator designated by the organization can access all information we collect about users that we make available through our web-based user interface. Organizational administrators can delegate the right to view information in accordance with organization policy.
Primary account holders who register as individual users can access all information available through our user interface relating to such user’s interactions with the Software. They cannot see information that we collect in connection with any other user’s interactions with the Software.
What Does TMT Do With Personal Information?
We do not ask or require users to provide information beyond that which is reasonably necessary to use the Software. We do not share any login information with any third party and we do not automatically collect personal information from accounts. Information collected from users is never used or disclosed for any third party advertising or any kind of behaviorally targeted advertising. We do collect website usage information through third party analytics services and Anonymized Data to help us improve our experiences for users, but such information does not contain personal information.
We use personal information and any other information collected through the website for the following reasons:
- to administer our website and access to our Software;
- to improve the quality and types of services that we deliver;
- to analyze Software usage and the popularity and performance of our Software products;
- to communicate with organizations by responding to your requests, comments and questions;
- to obtain consent from you and appropriate organizations so that an account may be created;
- to diagnose technical problems;
- to send users emails regarding service, technical and other administrative matters. These communications may also include information regarding changes in services, new service offerings and important service-related notices, such as security and fraud notices. Such communications will only be delivered to primary account holders;
- to send users alerts to notify them about pertinent activity on the Software, such as messages from colleagues or upcoming deadlines (“Notification Alerts”). These Notification Alerts may be sent to all users of the Software;
- to provide useful analyses to users and primary account owners;
- for billing, account management and other administrative matters; or
- as required by applicable law or regulation.
We use this information to help us to diagnose technical problems, administer the Software and improve the quality and types of services that we deliver. We may also collect, track and analyze information in aggregate form that does not personally identify users.
How We Share Information
When an organization is the primary account holder, we share information with third parties at the direction of the organization, and it is the organization’s responsibility to make such requests in a manner that is consistent with their internal policies and the law. We may also share information that we collect in the following circumstances:
- if we believe in good faith that it is necessary to disclose the information under any applicable law or regulation (for example, in response to a court order or a subpoena);
- if we believe in good faith that it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person;
- with third party products specifically configured by organizational clients to interoperate with the Software;
- if the information is Anonymized Data;
- with our corporate affiliates and/or subsidiaries; or
- in other circumstances in which you expressly consent.
Please also note that our service providers may be able to combine the data we share with them with the data they collect on their own. For example, if we share information with Google, Google may combine such information with the data they have already collected about you through their website. We are not responsible for such combinations of data and we encourage you to learn about their privacy and security policies before you use this Software or provide our service providers with your personal information.
Third Party Websites
Our Software may include some links to other sites. We are not responsible for the data collection practices on those other sites. We advise you to carefully review those sites’ privacy policies before submitting personal information there.
Our Security Practices
We strive to protect the confidentiality, security and integrity of the personal information we collect from you. We have put in place physical, electronic and administrative procedures to safeguard and to help prevent unauthorized access to and maintain the security of personally identifiable information collected through this Software.
Primary accounts are protected by passwords. Please keep these passwords secret to prevent unauthorized access to these accounts. If you think someone has gained unauthorized access to an account, please contact us immediately at firstname.lastname@example.org.
We take reasonable, industry standard measures to protect the confidentiality, security and integrity of personal information collected by our Software. This includes the use of encryption, firewalls and other security technologies to prevent access to the data from unauthorized parties. All connections between users and our Software are secured via encryption communication technology (SSL/TLS). All passwords are salted and hashed using the practices recommended by NIST (National Institute of Standards and Technology). We use highly rated application hosting providers who agree to perform frequent diagnostics, operating system updates, and network security monitoring. Our engineering team is committed to creating and maintaining systems to protect personal information.
Only employees who need to access user information in order to perform their job (for example, customer service) are granted access to information.
While we have taken all steps to protect the personal information we collect, and we work to keep our systems in line with industry standards, no system is 100% fail proof and secure. If we discover that the security of personal information has been compromised, we will notify you or the organization that established an account with us no more than thirty (30) days after the discovery of such compromise. We will conduct an investigation to determine the scope of the breach or restore the integrity of our system. You consent to our use of email as a means of such notification.
Your Choices Related to Your Privacy
In order to process your information, we rely on your consent or our legitimate interests to process your data. You may withdraw your consent or object to the use of our information at any time, but you may no longer be able to access TMT’s platform or the Software.
If you have a TMT account, you can edit your information in the account section of the Software. If you are unable to do this through our Software, you can contact us at email@example.com and we’ll help you make changes. We may ask you to verify your identity before we provide you with access to your information.
You have the right to opt out of emails from us by clicking unsubscribe. You may still receive transactional emails from us related to forgotten passwords, account expiration, or other necessary communication.
How You Can Delete or Edit Information or an Account
Please note that any information you share with others when using TMT’s platform or the Software or content other users may have copied, is not a part of your account and may not be deleted when you delete your account. If we share your data with one of our service providers, we will use our best efforts to cause such third party to delete such data when you delete your account.
How We Retain and Delete Your Data
We will retain personal information collected in connection with an account only for as long as is necessary to provide the services to the account holder, as required by applicable laws or regulations or otherwise per the terms or a contract with an organizational client.
We may maintain Anonymized Data, including usage data, for analytics purposes.
Certain Rights for EEA Persons
Individuals in certain countries, such as the European Economic Area (the “EEA”), have certain statutory rights in relation to their personal data. These rights include the right to request access to personal data, as well as to seek to update, delete or correct their personal data. You may exercise these rights by following the steps explained above, which for holders of accounts means making such a request to the primary account holder. If you have any problems exercising your rights or if you have any additional questions about our use of your personal data, please contact us at firstname.lastname@example.org for additional information.
Data Protection Officer; Data Protection Authority
TMT has a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at email@example.com.
You may direct questions to the Data Protection Officer. You also have the right to (i) restrict TMT’s use of information that constitutes your personal data, which will cause you to lose access to TMT’s platform and the Software, and (ii) lodge a complaint with your local data protection authority.
Identifying the Data Controller and Processor
We endeavor to be fully compliant with the General Data Protection Regulation (“GDPR”), effective as of May 25, 2018. TMT operates in the United States and TMT’s operations are subject to United States law. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and stored in the United States or other countries that may have data privacy laws that are less protective than the laws where you reside. Subject to the foregoing limitations, we may act, depending on the circumstances, as either or both a Controller and a Processor of personal data (as those terms are defined in the GDPR). We act as the Controller of information when we ask you to provide to create an account and information that we automatically collect when you use the Software. We act as the Processor of user-generated content and information provided to us by organizational clients.
Location of Data and Processing
Notice of Changes to This Policy
You may contact us at firstname.lastname@example.org