Privacy Policy

TPV Solutions Corp., (hereinafter referred to as “TPV”, the “Company”, “We”, “Us” or “Our”) values the privacy of user information provided to us and is dedicated to upholding the confidentiality of personal data we collect. As part of our commitment to privacy, we want to inform you about our practices for collecting and utilizing the information you provide us with

Definitions:

For the purposes of this Privacy Policy:

  • “Account” means a unique account created for You to access our Platform or or parts of our Platform.

  • “Business”, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

  • “Consumer”, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

  • “Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.

  • “Device” means any device that can access the Platform such as a computer, a cell phone or digital tablet.

  • “Do Not Track (DNT)” is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

  • “Personal Data” is any information that relates to an identified or identifiable individual. For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.

  • “Personally identifiable information (“PII”)” is any information that can be used to identify, contact, or locate an individual, either alone or combined with other easily accessible sources. It includes information that is linked or linkable to an individual, such as medical, educational, financial and employment information. Examples of data elements that can identify an individual include name, fingerprints or other biometric (including genetic) data, email address, telephone number or social security number.  Unless otherwise indicated, references herein to PII include sensitive PII (as defined below).

  • “Sensitive PII” means data that is a subset of PII that indicates an individual’s racial or ethnic origin, financial account information, political opinions, religion, union membership, sexual orientation, medical or health condition or actual or alleged criminal activity.

  • “Sale”, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.

  • “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Platform, to provide the Platform on behalf of the Company, to perform services related to the Platform or to assist the Company in analyzing how the Platform is used.

  • “Usage Data” refers to data collected automatically, either generated by the use of the Platform or from the Platform infrastructure itself (for example, the duration of a page visit)

  • “Website” accessible from www.tpvsolutions.com

  • “You” means the individual accessing or using the Platform, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform, as applicable.

Types of Data Collected

Personal Data:

When you use our Platform, we may request that you provide us with personal information that can be used to contact or identify you. This information may include, but is not limited to:

  • Email address

  • First and last name

  • Phone number

  • Address, state, province, ZIP/postal code, city

  • Usage data

Usage Data:

The Platform collects Usage Data automatically as you use it. This data may include:

  • Your device’s internet protocol (IP) address

  • Browser type and version

  • Pages visited on the Platform

  • Date and time of visit

  • Time spent on Platform pages

  • Unique device identifiers

When you use a mobile device to access the Platform, we may also collect certain information automatically, such as the type of device you’re using, its unique ID, your mobile device’s IP address, your mobile operating system, the type of mobile internet browser you use, and other diagnostic data.
Additionally, we may collect information that your browser sends whenever you visit our Platform or access it through a mobile device.

Tracking Technology and Cookies:

We use cookies and similar tracking technologies like beacons, tags, and scripts to gather and store information, analyze and improve our Platform. The specific technologies we use may include:

  • Cookies or browser cookies: These are small files that are placed on your device. You can configure your browser to refuse all cookies or to notify you when a cookie is being sent. If you choose not to accept cookies, certain parts of our Platform may not be accessible to you. Our Platform may use cookies unless you have set your browser to reject them.

  • Web beacons: Certain parts of our Platform and emails may contain electronic files such as web beacons, clear gifs, pixel tags, or single-pixel gifs. These files allow us to count users who have visited certain pages, opened emails, and gathered website statistics like popularity of certain sections, and verify system and server integrity.

Your Use of the Website/Platforms Implies Your Consent

Your use of TPV Websites or Platforms signifies your acceptance of this Privacy Statement. If you do not agree or are not comfortable with any policy described in this Privacy Statement, your remedies are to discontinue your use of the relevant website.

Information We Share, Disclosures

We do not share your personal information with third parties other than as follows:

  • Service Providers. We may share personal information with authorized third parties who provide services to accomplish Client objectives. This includes third-parties, other than our client, if (a) the individual has granted consent to the Client or Company via methods listed in ‘Choice and Consent’ section above, (b) the disclosure is necessary to meet national security, public interest, or law enforcement requirements or (c) allowed by a law that creates conflicting obligations for the Company or that explicitly authorizes disclosure (except that we will limit such disclosure to the extent necessary).

    These third parties must maintain agreements with the Company that ensures they will protect an individual’s personal information in a manner consistent with relevant aspects of this Privacy Policy.

  • Third Party Verification Services. We may share limited personal information (e.g., address, phone number) with non-TPV entities to assist with identity verification, and to prevent fraud and identity theft.

  • The Company restricts access to PII internally to TPV agents and partners, who need to know that information in order to operate, develop or improve our services. These parties are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

  • The Company reviews and performs a risk analysis prior to contracting with a third-party that collects, handles, processes, stores or protects personally identifiable information are reliable, operate fairly and lawfully and maintain the controls necessary to meet the terms of the Business Agreements and this policy.

     

  • The Company provides copies of the Privacy Policy to third parties that collects, handles, processes, stores or protects personally identifiable information prior to engagement and at least once a year.

  • The Client is responsible for monitoring and enforcement of security measures in regard to collection of personal information about their data subjects.

     

  • The Company maintains controls in attempt to prevent the misuse of personal information by third parties and mitigates, to the extent practicable, any harm caused by the use or disclosure of personal information by a third-party in violations of the privacy policies and procedures and will take remedial action on any third-party that misuses personal information.

     

  • The Company will maintain a record of detected and reported unauthorized disclosures of personal information that is reviewed annually for completeness, accuracy, and timeliness.

Data Retention & Disposal

Consistent with any applicable service commitments, the Company does not retain PI/PII longer than necessary to fulfill the stated business purposes unless a law or regulation specifically requires otherwise.

Consistent with any applicable client commitments and government regulations, the Company maintains processes that captures, identifies and flags PI/PII for destruction in a manner that data becomes entirely unreadable (destroyed/anonymized or redacted) and unable to be reconstructed/reconstituted, thereby preventing information loss, theft, misuse, or unauthorized access.

Security

The company takes security measures designed to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These measures include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures designed to guard against unauthorized access to systems where we store PII.

Changes in this Privacy Statement

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here and by means of a notice on our home page, your program website, another appropriate place or by email.

Testimonials

We occasionally post customer testimonials on our web sites which may contain Personally Identifiable Information such as the customer’s name. We obtain the customer’s consent prior to posting any testimonials.

Security for Privacy/Data

Ensuring the security of your personal information is a top priority for us. We adhere to industry standards widely recognized as acceptable for protecting personal information during transmission and storage. Despite our efforts to protect your personal information, no method of transmission or electronic storage is entirely foolproof. As a result, we use commercially reasonable measures to safeguard your personal information, but we cannot guarantee its absolute security.

Information We Collect

When you first visit our website, we may request additional information from you, such as your name, employer’s name, address, telephone and fax number, email address, and other contact and identity details. If you choose not to provide this information, we may be unable to provide you with our Platform. If you do submit personally identifiable information, we will use it for the purposes stated at the time of submission and may contact you about other relevant services. However, you can still access our publicly available content anonymously without registering. TPV gives users the option to opt-out of disclosing their personally identifiable information to third parties or using it for a purpose other than its original intention. For sensitive information, users must opt-in to allow such data to be disclosed or used. To exercise opt-out rights, users should contact us via email at [email protected].

How We Use the Collected Information

We may use the information collected from and about you in various ways, including but not limited to:

  • Fulfilling your requests

  • Providing you with information about offers we think you might find useful

  • Notifying you of updates to the Sites, changes to our services or products, or new products and services that may be of benefit to you

  • Combining information, you have given us offline with the information provided online to personalize your experience on the Sites

  • Retaining all data for at least the minimum period required by law.

  • Please note that this list is not exhaustive, and we may use the information collected from you for other purposes as well.

Information We Share

We value your privacy and do not disclose your personal information to third parties except for the following reasons:

  • Service Providers: We may share your personal information with third-party service providers who perform tasks on our behalf.

  • Third-Party Verification Services: We may share limited personal information, such as your address and phone number, with non-TPV entities to help verify your identity and prevent fraud and identity theft.

  • Please note that we do not sell or rent your personal information to any third party for marketing purposes.

Choice & Consent

TPV allows Users from whom it collects PII the opportunity to choose not to allow the Company to disclose his or her PII to a third party or to use it for a purpose incompatible with the purpose for which it was originally collected (the “opt-out” rights). For Sensitive PII, TPV requires such User to affirmatively choose to allow for the data is to be disclosed to a third party or used for a purpose other than its original purpose (the “opt-in” choice).

Users desiring to exercise their opt-out rights should first contact us by email at Hello@tpvsolutions.com

  • Personal information is collected only with those who have, are interested in, or are in the process of requesting information on, or establishing a business relationship with the Company and have obtained consent (explicit or implied).

  • The Company will ensure the individual has obtained consent to share their personal information (transfer to or from) with Third Parties before doing so.

  • The Company will work with individuals who request removal of, or updates to, their personal information as allowed by business requirements or relevant Laws & Regulations.

  • When the Company intends to use personal information that was previously collected for purposes not previously identified in the privacy notice, the individual will be notified, and consent will be obtained prior to such new use or purpose.

  • The Company will maintain documentation of explicit consent for the collection, use, or disclosure of personal information on the public websites.

Onward Transfer to Third Parties

The Company may disclose PII to a third party if (a) the Company has received the applicable User’s permission to make the disclosure, (b) the disclosure is necessary to meet national security, public interest, or law enforcement requirements, (c) allowed by a law that creates conflicting obligations for the Company or that explicitly authorizes disclosure (except that we will limit such disclosure to the extent necessary), or (d) the Principals allow for other exceptions provided that it is applied to other Users equally.

The Company may only disclose PI/PII to third parties for new purposes or uses only with the prior implicit or explicit consent of the individual.

CCPA Privacy Policy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

We collect 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. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

  • Category A: Identifiers: Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

    Collected: Yes
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

    Collected: Yes
  • Category C: Protected classification characteristics under California or federal law.: Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

    Collected: No
  • Category D: Commercial information: Examples: Records and history of products or services purchased or considered. Collected:
  • Category E: Biometric information: Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

    Collected: No
  • Category E: Biometric information: Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

    Collected: No
  • Category F: Internet or other similar network activity: Examples: Interaction with our Service or advertisement.

    Collected: Yes
  • Category G: Geolocation data: Examples: Approximate physical location.

    Collected: Yes
  • Category H: Sensory data: Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

    Collected: Yes
  • Category I: Professional or employment-related information: Examples: Current or past job history or performance evaluations.

    Collected: No
  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

    Collected: No
  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

    Collected: No
  • Category K: Inferences drawn from other personal information: Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    Collected: No

    Under CCPA, personal information does not include:
  • Category K: Inferences drawn from other personal information: Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.Publicly available information from government records
    Collected: No

    Under CCPA, personal information does not include:
  • Publicly available information from government records

  • Deidentified or aggregated consumer information

  • Information excluded from the CCPA’s scope, such as:

  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data

  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from You. For example, from the forms You complete on our Platform, preferences You express or provide through our Platform, or from Your purchases on our Platform.

  • Indirectly from You. For example, from observing Your activity on our Platform.

  • Automatically from You. For example, through cookies We or our Platform Providers set on Your Device as You navigate through our Platform.

  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our Platform, third-party vendors for payment processing, or other third-party vendors that We use to provide the Platform to You.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
  • The categories of personal information We collected about You

  • The categories of sources for the personal information We collected about You

  • Our business or commercial purpose for collecting or selling that personal information

  • The categories of third parties with whom We share that personal information

  • The specific pieces of personal information We collected about You

  • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
  • The categories of personal information categories sold

  • The categories of personal information categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
  • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.
    Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
  • Denying goods or services to You

  • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

  • Providing a different level or quality of goods or services to You

  • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.
Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative

  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

  • Verify Your identity or authority to make the request

  • And confirm that the personal information relates to You

  • We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily usable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact us.


The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Platform that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.


Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Children’s Privacy

Our Platform does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

 

Links to Other Websites

Our Platform may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.


Contact Us

You have any questions about this Privacy Policy, You can contact us: