A) General Provisions
1. Who we are.
TLUX Technologies, 152-160 City Road, London, EC1V 2NX, (“TLUX Technologies Limited”) is generally responsible for and controls the processing of your personal information with respect to personal information collected through the Services.
The expressions “TLUX,” “we” and “our” include TLUX Technologies Limited and any other TLUX group company from whom you retain Services.
2. Global applicability and region-specific disclosures.
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain countries, regions or states. Please refer below for disclosures that may be applicable to you:
The processing covered by the EEA-specific privacy disclosures contained in section B include our processing of your personal information relating to individuals in the European Union, the UK (if the UK is not a member of the European Union), Switzerland, Liechtenstein, Norway and Iceland – all of which will, for the purpose of this notice, be defined as the “EEA” – and if we either offer goods or services to such individuals or monitor their activities in the EEA, or where the processing takes place in the EEA. Please click here for additional EEA-specific privacy disclosures.
3. What is personal information?
4. What personal information do we collect?
In the context of rendering our Services, we may collect information about you. This information regularly includes the following:
- If you order any Service from us or ask for a quote (via our Websites or via phone, email or letter): This in particular includes: Your name, company name, company address, billing contact, billing address, company email address, company phone number, job title, job function, industry, price and Service information and customer ID. If you render services as our customers, we may in particular also process the following personal information: Log-in ID, password, employee ID, employment status, manager, your corporate unit and cost centre, account name, IP address, computer and device information (such as MAC address, computer/device name, host name, calculated user, hardware dongleID, UUID and FQDN). But we also may process information we need to contact you or otherwise communicate with you, information for order fulfilment and delivery of requested materials or services as well as maintenance and training associated with our Services, information to manage your account, information to enable the download or usage of Services, information on defects or erroneous Services, your feedback and complaints, quotes we offer you and information for invoicing and payment follow-up.
- If you register on our Websites: Name, company name, company address, company email address, company phone number, job title, job function, industry and your interest(s) in TLUX and/or its Services.
- If you contact us (via our Websites or via phone, email or letter), e.g., for a support request: Name, company name, company address, company email address, company phone number and information on our communication with you, your interest(s) in TLUX and/or its Services and any additional information you provide us with.
- If you merely use our Websites: IP address, browser data, device type, Uniform Resource Locators (URL), operating system, site preferences and information on your usage of our Websites.
- If you participate in our events, such as webinars, and trade fair booth events, or if you download our white papers: Name, company name, email address, phone number, address, position/job title, job function, job level and any information on the event or download.
- If you are in our email marketing campaigns: Name, company name, email address, phone number, address, position/job title, job function, information about whether you are already a customer, marketing campaign information such as the newsletter option you have selected and your reaction to our marketing and your interest in our products.
5. How do we collect your information?
This personal information is collected in many ways and may include:
- Personal information you provide to us. Most of the personal information we receive comes to us voluntarily from our users in the course of using our Services, communicating with us in the procurement of or in the process of requesting our Services, registering to attend a seminar or participate in a survey, interacting with us at trade shows or conventions or other industry events or asking to be included in an email or other communication list, or other product promotions.
You are free to choose which information you want to provide to us or whether you want to provide us with any information at all. However, some information, such as your name, address, payment information and information on your requested Services may be necessary for the performance of our contractual obligations. Without providing this information, you will not be able to order certain Services or enter into a contract with us.
- Personal information we receive from others. We may receive personal information about users from publicly available databases or third parties from whom we have purchased data, third parties such as social media sites, law enforcement agencies, providers of denied party screening and marketing consultants and partners. We may also receive personal information, such as contact details, including name, position, phone or email address from our partners and customers.
6. Why we collect and use your personal information?
The reasons for using your personal information may differ depending on the purpose of the collection. Regularly, we use your information for the following purposes:
- Providing our Services. If you order Services from TLUX or if you contact us to request our Services, we use your information to provide you with these Services.
- Pursue our business interests. The usage of your information may also be necessary for our own business interests. For example, we may use some of your information to evaluate and review our business performance, create financial statements, improve our Services, provide advertising or to identify potential cyber security threats. We may use your information for marketing purposes, for example, to send you relevant product updates and/or share your contact information such as name, email address or phone number with reseller partners for them to directly contact, qualify and manage the customer relationship. In the case that a reseller partner uses your contact details for own marketing purposes, we or the reseller will do so only if you have granted a respective separate consent. If necessary, we may also use your information to pursue or defend ourselves against legal claims.
- Purpose for which consent has been provided. In some cases, we may ask you to grant us separate consent to use your information.
If you have granted us consent to use your information, we will use it only for the purposes for which you have granted your consent. You are free to deny your consent and the denial will have no negative consequences for you. You are also free to withdraw your consent at any time with effect for the future.
- Comply with legal obligations. We are obligated to retain certain information because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide personal information on request.
7. With whom do we share your personal information?
As required in accordance with how we use it, we will share your personal information with the following third parties:
- Service providers and advisors. We may use third party vendors and other service providers to perform services on our behalf. Such services may include marketing campaign services, providing mailing or email services, tax and accounting services, product fulfilment, payment processing, conducting surveys or contests, performing customer service, performing data enhancement services, performing fraud prevention services, performing web hosting services or providing analytic services. These third parties, whose services TLUX Software regularly uses include, in particular: QuickBooks, Amazon and WordPress. Any such service providers will by appropriate data processing agreements be bound to only process the data on TLUX’s behalf and under its instructions, unless such service providers act as their own controllers (e.g., in the case we seek advice from lawyers and tax consultants).
- Promotional partners. Third parties with whom we partner to provide promotional activities, which will be identified by name in the context of these activities. We may, for example, share contact details with reseller partners.
- Purchasers and third parties in connection with a business transaction. Third parties in connection with a TLUX-related transaction, such as a merger, sale of TLUX assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, or in the event of a bankruptcy or similar proceedings.
- Law enforcement, regulators and other parties for legal reasons. Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our legal claims or to protect the security or integrity of our Services; and/or (c) to exercise or protect the rights, property or personal safety of TLUX employees, our visitors or others.
- The public, when posted in certain public spaces. Remember, our Websites allow you to connect and interact with others. Your profile information or information that you post in a forum or on a blog, including personal information, will be available publicly to other members of the Websites by default when you create a profile, post in a blog or forum or interact with others on the Websites in public groups and post content to public spaces.
- Otherwise with consent. We may disclose an individual’s personal information to certain other third parties with that individual’s consent.
8. How do we safeguard your personal information when there is an international transfer?
As TLUX is located in the UK, any information you provide will be processed and stored in the UK.
Further GDPR-specific information regarding the safeguards we have in place can be obtained here.
When using our Services, we and our third-party partners may automatically collect certain types of usage information. For this purpose, we often rely on tracking technologies, including cookies, web beacons, embedded scripts and similar technology (collectively, “Tracking Technologies”) in accordance with this policy. Where legally required, we will inform you about the use of such tracking technologies using so-called cookie-banners and/or obtain your consent to use such Tracking Technology.
- How do these Tracking Technologies work? Cookies are pieces of code that allow for personalization of the Services experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device’s hard disk (such as your computer or smartphone) for record-keeping purposes. Cookies store certain settings and data for exchange with our system via your browser. A cookie usually contains the name of the domain from which the cookie has been placed, as well as information about the age of the cookie and a random alphanumeric identifier, the so-called cookie-ID. They help to recognize the device and make any pre-settings immediately available. Web beacons are small graphical images that may be included on our Sites and typically work in conjunction with cookies to identify our users and user behaviour. An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer or device from our web server or a third-party service provider, is active only while you are connected to the Site and is deactivated or deleted thereafter. Flash cookies are pieces of data that websites which use Adobe Flash may store on a user’s computer or device. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity often use flash cookies.
- What information do these Tracking Technologies collect? These tracking technologies collect information about your browser and online usage patterns (e.g., IP address, pages you view, the links you click and other actions you take on the Services such as opening an email, log files, browser type, browser language, referring/exit pages and URLs, etc.), and information about the device(s) you use to access the Services (e.g., unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (IDFA), Google AdID or Windows Advertising ID), device type, model and manufacturer, operating system brand and model and, depending on your mobile device settings, your geographical location data). We, or our third party partners, may link your various devices so that content you see on one device can result in relevant advertising and content displayed on another device so that we may recognize and contact you on the various devices you may use.
- What are Cookies and other Tracking Technologies used for? Tracking Technologies do lots of different jobs, like helping us understand how our Websites are being used, helping us analyse trends, administering the Websites, tracking users’ movements around the Websites, gathering demographic information about our user base as a whole, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience. Tracking Technology can also help ensure that you see marketing content that is more relevant to you and your interests. Therefore, generally speaking, we use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Website(s); (b) provide custom, personalized content and information, including targeted content and advertising; (c) recognize and contact you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage and demographic patterns on our Websites; (f) diagnose or fix technology problems; and (g) otherwise plan for and enhance our Services.
- What types of cookies are used by TLUX? The types of cookies used on our site can generally be put into one of the following categories: Necessary; functional and advertising. You can find out more about each of the cookie categories in the table below.
- Necessary Cookies. These cookies are essential to make our Websites work. They enable you to move around the Websites and use their features. Without these cookies, services that are necessary for you to fully use our Websites may not be available, such as accessing certain areas of the Websites.
- Functional Cookies. These cookies allow us to recognize you and tailor our Websites to provide enhanced features and content to you. For example, these cookies can be used to remember your IP address, language choice, country selection and requested Services.
- Advertising Cookies. These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and may track you on other websites. This information may be shared with other organizations such as advertising partners.
- How long will cookies stay on your browsing device? The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing the website that has set the cookie. Persistent cookies stay on your browsing device after you have finished browsing a particular website, until they are deleted or until they expire. The actual period of validity of each persistent cookie depends on each cookie. However, they generally expire within 3 months. You can amend your cookie settings using your your internet browser’s settings.
- Interest-based advertising. We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Services, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Services. Typically, this information is collected through cookies and similar tracking technologies. Where legally required, we will obtain your consent.
If you only want to limit third-party advertising cookies, you can turn such cookies off by visiting the following links (please bear in mind that there are many more companies listed on these sites than those that drop cookies via our website):
- Your Online Choices (http://www.youronlinechoices.com/)
- Network Advertising Initiative (http://www.networkadvertising.org/)
- Digital Advertising Alliance (http://www.aboutads.info/consumers)
- TRUSTe’s Opt-out Tool (http://preferences-mgr.truste.com
- How can you manage cookies from our Websites? The cookies we use are designed to help you get the most from our Services, but if you do not wish to receive cookies, most browsers 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) disable existing cookies; or (iii) set your browser to automatically reject cookies. You can also avoid Tracking Technology by not consenting to the use of Tracking Technology when asked for consent in cookie banners. Please check your browser and browser settings to determine where cookies are stored and whether and how they may be deleted. The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie or how to disable most cookies altogether. Depending on your mobile device and operating system, you may not be able to delete or block all Tracking Technologies. Please note that in the case you delete existing cookies, your chosen pre-settings will be deleted as well. This means that the next time you access our website, we may ask for your consent again (to the extent required by law) and set new cookies. The period of validity of those cookies will then start from the beginning. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it. In order to understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
- We use Demandbase to help us provide you with targeted ads on the basis of cookies and online search behaviour. If you do not wish to receive such ads, you can use the means set out above and also choose to withdraw your consent (if provided before) or opt-out by using the means provided here.
10. Social media.
11. Links to other Websites and services.
The Services may contain links to and from third-party websites of our business partners, advertisers and social media sites, and our users may post links to third-party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, share and otherwise process information. We are not responsible for the privacy practices or the content on the websites of third-party sites.
12. How do we protect your personal information?
We implement a variety of security measures designed to maintain the safety of your personal information when you use our Services.
However, no security system is impenetrable, and we cannot guarantee the security of our systems 100%. In the event that any personal information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose personal information may have been compromised, such notification will be made having regard to the nature of the personal information involved and may include email communications, written correspondence, or public statements and take other steps in accordance with any applicable laws and regulations, such as notify competent data protection authorities.
13. Children’s privacy.
For EEA-specific information on children’s privacy, please our section “Additional information on children’s privacy”.
14. What rights and choices do you have?
We want you to understand your rights and choices regarding how we may use your personal information. Depending on how you use your information, these rights and choices may include the following:
- Access, correction and deletion. Upon request, TLUX will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at info@TLUX-group.com. We will respond to your request within a reasonable timeframe.
- EEA-specific rights. For further EEA-specific rights, please see our section “Additional GDPR specific disclosures.”
16. How to contact us?
TLUX, 152-160 City Road, London, EC1V 2NX
17. Data Compliance Team.
For all enquiries regarding TLUX’s data processing activities, you may also want to contact our Data Compliance Team, who can be reached at info@TLUX-group.com.
B) Additional GDPR-specific disclosures
18. Scope of the disclosure.
19. Information on data processing rendered by us on behalf of customers.
Where a TLUX group company processes personal information based on a data processing agreement entered with you or your employer (or other similarly situated entity), the respective TLUX group company is not the data controller but a data processor within the meaning of Art. 4(8) GDPR.
The use of information provided to us as a data processor by our customers for the purpose of processing on their behalf shall be limited to the purpose of providing the Service for which the customer has engaged TLUX (data processing on behalf of customer).
TLUX acknowledges that you have the right to access your personal information. TLUX has no direct relationship with the individuals whose personal information it processes on behalf of its customers. An individual who seeks access or who seeks to correct, amend or delete inaccurate data should direct their query to TLUX’s customer (the data controller). If requested to remove data we are processing for our customer, we will respond within a reasonable timeframe. We may transfer personal information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the service agreements with our customers.
20. Legal basis based on which we collect and use your personal information.
Regularly, we use your personal information based on the following legal grounds:
- Perform of our contractual services or prior to entering into a contract with you. If you order Services from TLUX or if you contact us to request our Services, we use your information to provide you with these Services.
- In some cases, we may ask you to grant us separate consent to use your information. You are free to deny your consent and the denial will have no negative consequences for you. If you have granted us consent to use your information, we will use it only for the purposes for which the consent has been granted. You are also free to withdraw your consent at any time with effect for the future.
- Compliance with legal obligations. We are obligated to retain certain information because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide personal information on request.
We do not use your personal information for automated individual decision-making.
21. How long do we keep your information?
We will store personal information for as long as necessary to fulfil the purposes for which we collect the personal information, and in accordance with our legal obligations and legitimate business interests. Personal information collected in connection with the Websites by Eloqua that offers marketing services will be identified for manual removal after 18 months of no interaction between the data subject and TLUX. Additionally, personal information processed by TLUX as a data processor will be removed in accordance with the instructions of the applicable data controller.
If you signed up for our promotional emails, we will delete the respective personal information if you unsubscribe from receiving our promotional emails. However, we will store your email address in a black list to ensure that you will not receive any further communication.
22. Additional EEA-specific information on children’s privacy.
From children under the age of 16 residing in the EEA, we will not process any personal information on the ground of a consent.
23. EEA-specific rights.
If you are in the EEA or if your personal information is processed by a TLUX group company located in the EEA, you have the following rights in respect to your personal information that we hold:
- Right of access. The right to obtain access to your personal information.
- Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain restriction of the processing undertaken by us on your personal information in certain circumstances, such as, where the accuracy of the personal information is contested by you, for a period of time enabling us to verify the accuracy of that personal information.
- Right to portability. The right to portability allows you to move, copy or transfer personal information easily from one organization to another.
- Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. You can object to marketing activities for any reason whatsoever.
This document was last updated May 4th 2020