TTI PRIVACY POLICY

We, that is TTI, Inc., are the data controller. We are responsible for, and control, the processing of your personal information.

If you wish to contact us, you can find our contact details at the end of this privacy policy.

When you use our Services, we may collect information about you. This information regularly includes the following:

• If you order any Services from us or ask for a quote: Name, company, shipping and billing address, email address, phone number, job title, information from our correspondence with you; information on your order or quotes, such as price and parts information, information on the return of shipment, defects or erroneous products, your feedback and complaints, quotes we offer you, customer ID, information on your TTI customer account; payment information such as bank account details, credit card information, or check information; information on outstanding payments; VAT number.
  • If you are paying by credit card:
    We will not keep credit card numbers. Your credit card information is tokenized the first time it is processed. Should you elect to save a credit card to your account for future use, only the encrypted token is stored and used to charge your credit card account. TTI integrates with regional payment processors globally such as Chase Paymentech Orbital and Saferpay.
• 
  If you register on our website:
  
  Name, company, address, email address, phone number, job title; as well as any kind of information you provide us with.
• 
  If you contact us (via our website or via phone, email or letter):
  
  Name, company, job title, address, email address, phone number and any additional information you provide us with.
• 
  If you use our website:
  
  IP address, browser data, browser type, device type, device ID, Uniform Resource Locators (URL), operating system, part search and detail requests, information on your usage of our website, including your use of our online applications ezReview, ezBill, ezBuy, Order Status, Project List and BOM when registered and signed into the website.
• 
  If you are in our email marketing campaigns:
  
  name, email address, title, address, industry, region, information whether you are already a customer, marketing campaign information, such as your reaction to our marketing and your interest in our products.

This personal information is collected from you in many ways, and may include:

• Personal information you provide to us:
  The majority of personal information we receive comes to us voluntarily from our users in the course of using our Services, such as when visiting our website, communicating with us or in the ordering process.
  You are free to choose which information you want to provide to us or if you want to provide us with information at all. However, some information, such as your shipping address, payment information and product order information are necessary for the performance of our contractual obligations. Without providing this information, you will not be able to order Services from us.
• Personal information collected via technology:
  As you use our websites, we may collect passive information through the use of cookies. Please see below for more information.
• Personal information we receive from others:
  We may receive personal information about users from third parties such as web analytics vendors, social media sites, law enforcement agencies, providers of denied party screening and marketing consultants. We receive information on the purchases of shared customers with the TTI family of companies for marketing purposes and lead generation. In addition, when you interact with us through a social media site or third-party service, such as when you like, follow, or share TTI content on Facebook, Twitter, or other sites, we may receive information from the social network, including your profile information, picture, user ID associated with your social media account, and any other information you permit the social network to share with third parties.

GDPR Notice:

The reasons for using your personal information may differ depending on your interaction with us. Regularly we use your information for the following purposes and on the following legal grounds:

We use your information in order to perform our contractual services or prior to entering into a contract with you.

If you order Services at TTI or if you contact us to order Services, we use your information to provide you with these Services. Information we use for this purpose includes: information we need to contact you and communicate with you; information we need in order to provide you with individualized offers (repricing, quoting); information to manage and execute your orders, also in the context of warehousing and shipping; information in the context of a possible return of your products and the evaluation of defects; information for invoicing; information provided in the context of using our online applications and payment follow up. The legal justification of these data processing activities is the need to perform a contract with you or to take steps at your request prior to entering into a contract. The data will be stored as long as it is necessary for the performance of the contract.

We use your information if justified by our legitimate 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, for advertising purposes or to identify potential cyber security threats. If necessary we may also use your information to pursue, or defend ourselves against, legal claims. If you use our website, we may also use your information to provide and improve our website services. We have a legitimate interest in performing these tasks as they are relevant for conducting our business. The legal justification of these data processing activities is thus the balancing of interest-based justification. The data will be stored as long as it is necessary for pursuing our legitimate interests.

We use your information after obtaining your consent.

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. You are free to withdraw your consent at any time with effect for the future and the withdrawal will not have negative consequences for you. If you have granted us consent to use your information, we will use it only for the purposes specified in the consent form. This especially includes our marketing campaigns. If you sign up to our email newsletter or, when providing us with your email address, allow us to use this email address for email marketing, we will use your information in our email marketing campaigns. You may unsubscribe from our email newsletter at any time by clicking on the “unsubscribe link” provided in such communications or by sending an email to privacy@ttiinc.com. The legal justification of such data processing activities is the consent you are granting us. If we use your email address for our email newsletter, we generally store the data until you unsubscribe from our newsletter. However, the legal justification to keep data stored for other purposes, e.g. keeping a blacklist to safeguard e-mail addresses will no longer be used for marketing purposes after unsubscribing, remain unaffected by this. The data will be stored as long as it necessary for the data processing activity.

We use your information to comply with legal obligations.

We are obligated to retain certain information because of legal requirements, such as for tax and business regulations, for example, tax or commercial laws. The legal justification of such data processing activities is our need to comply with applicable legal obligations. We store this data as long as we are required by law to do so. In this regard, statutory retention periods may require us to store your personal information for up to ten years.

We will only use your information for the purposes above. We will not use your information for other purposes. We do not use your personal information for automated individual decision-making.

As required in accordance with how we use it, we will share your personal information with the following third parties:

Delivery agents:

to ship your orders, we may share your name and shipping address with delivery agents, such as FedEx, UPS, Averitt, DHL, Central or DB Schenker International. The legal justification of data transfers is our duty to perform the contract with you.

Service providers and advisors:

third party vendors and other service providers that perform services for us or on our behalf, which may include marketing campaign services, providing mailing or email services, tax and accounting services, product fulfilment, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services. Any such service providers and advisors will be given limited access to personal information as reasonably necessary for delivering its service and will, by appropriate data processing agreements, be bound to only process personal information on our behalf and under our instructions. The legal justification of such data transfers is either the performance of the contract with you or the balancing of legitimate interests.

Promotional partners:

third parties with whom we partner to provide webinars or other promotional activities, which will be identified by name in the context of these activities. We have a legitimate interest in working with these partners. The legal justification of this data transfer is thus the balancing of interest;

Selected third parties:

third parties, so that they can provide you with information and marketing messages about products or services that may interest you, where you have given us separate consent to do so. The legal justification for the data transfer is your consent;

TTI Family of Companies:

We also share information on the purchases of shared customers with TTI subsidiaries for marketing purposes and lead generation. For this purpose, we have concluded a Controller Transfer Agreement with other companies in the TTI family in order to safeguard this transfer of data;

Purchasers and third parties in connection with a business transaction:

personal information may be disclosed to third parties in connection with a TTI-related transaction, such as a merger, sale of TTI assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another TTI entity or third party, or in the event of a bankruptcy or related or similar proceedings. We have a legitimate interest in transferring data in connection with a business transaction. The legal justification of this data transfer is the balancing of interest; and

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 products and service; and/or (c) to exercise or protect the rights, property, or personal safety of TTI, our visitors, or others. We are legally obliged to transfer the data in this scenario. The legal justification of such data processing activities is our need to comply with applicable legal obligations.

GDPR Notice:

We will store personal information for as long as necessary to fulfil the purposes for which we collect the personal information in accordance with our legal obligations and legitimate business interests. To ensure that all your data is deleted in accordance with the principle of data minimization, we have developed a data retention policy. The following describes the fundamental principles and outlines essential retention periods contained in this policy.

As a general rule, we keep data necessary for the performance of a contract for six up to ten years depending on the nature and scope of the contract in order to clarify any enquiries or claims after expiry of the contract. We need this information, e.g. in the context of a possible return of your products and the evaluation of defects or for compliance with statutory retention requirements, for example, tax laws.

We may retain any information that we deem necessary to investigate or defend claims against us, or to prosecute or bring claims against you, us or any third party, for as long as we believe such action may be necessary.

We may retain data collected from you for customer service and marketing purposes, for up to six years after collection, unless you object against the procession of your data for this purpose or you wish the data to be deleted and there are no contractual or statutory storage obligations that prevent this request for deletion.

In regard to business correspondence or documents relevant under commercial code or tax law, statutory retention periods range from six up to ten years. This legal data retention period covers, inter alia, invoices, vendor documents or financial statements.

We may store your device information and other technical information for legitimate business purposes.

We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, unauthorized change or damage. All personal information we collect will be stored on our secure servers. All electronic transactions entered into via our website will be protected by SSL encryption technology.

As we are located in the USA, any information you provide will be processed and stored in the USA. If you are in the European Union or European Economic Areas, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically a resident in.

For this reason, we have entered into guarantees to ensure appropriate safeguards. If we transfer information from the European Union to third parties outside the European Union and in countries or not subject to schemes which are considered as providing for an adequate data protection standard, we will enter into contracts which are based on the EU Standard Contractual Clauses with these parties.

If you wish to inquire further about the safeguards we use, please contact us using the details set out at the end of this Privacy Policy.

We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this Privacy Policy.

We, and our third-party partners, automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. You can usually change the settings of your browser to modify the permissions you give to us and third parties for the storing of and gaining access to cookies on your device.

• What are Cookies?
  Cookies are text files, containing small amounts of information, which are downloaded to your browsing device (such as a computer, tablet or mobile phones) when you visit a website. Cookies allow websites or ad networks to recognize a user’s internet browser. This helps websites to know if the browsing device has visited them before.
• What are Cookies used for?
  Cookies do lots of different jobs, like helping us understand how our website is being used, letting you navigate between pages efficiently, remembering your preferences and generally improving your browsing experience. Cookies can also help ensure marketing you see online is more relevant to you and your interests.
• What types of cookies are used by TTI and on what legal grounds do we process personal information?
  The types of cookies used on our site can generally be put into one of the following categories: strictly necessary; analytics; functionality; advertising; and social media. You can find out more about each of the cookie categories in the description below.
  • Strictly Necessary Cookies: These cookies are essential to make our website work. They enable you to move around the site and use its features. Without these cookies, services that are necessary for you to fully use our website may not be available, such as accessing certain areas of the website. We have a legitimate interest in the use and storage of these cookies for the technically flawless and optimized provision of our service and to carry out the electronic communication process in the functions you require. This data is therefore processed on the basis of Art. 6 para. 1 lit. of GDPR.
  • Analytics Cookies: These cookies collect information about how people are using our website, for example which pages are visited the most often, how people are moving from one link to another and if a particular user experiences error messages on certain pages. All information these cookies collect is grouped together with information from other people’s use of our website. Overall, these cookies provide us with analytical information about how our site is performing and how we can improve it.
  • Functionality Cookies: These cookies allow us to remember choices you make and tailor our website to provide enhanced features and content to you. For example, these cookies can be used to remember your username, language choice or country selection, they can also be used to remember changes you’ve made. The legal justification of these data processing activities is either performance of contract or the balancing of interests as there is legitimate interest in providing a better user experience through an optimized provision of our service.
  • Advertising Cookies: These cookies are used to deliver advertisements that are more relevant to you and your interests. Please see the section below on “Third Party Tracking and Online Advertising.”
  • Social Media Cookies: In order to enhance your internet experience and to make the sharing of content easier, some of the pages on our website may contain tools or applications that are linked to third party social media service providers such as Facebook, Twitter or Google+. Through these tools or applications the social media service provider may set its own cookies on your device. We do not control these cookies and you should check the social media service provider’s website for further details about how they use cookies.
• 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 maximum duration for analytics cookies is two years. You can delete the cookies in the security settings of your browser at any time.
• First and third party cookies: “First party cookies” are cookies that belong to us and that we place on your device. “Third-party cookies” are cookies that another party places on your browsing device when you visit our website. Third parties setting cookies from our website will be providing a service to us or a function of the website but we do not always control how third party cookies are used. Some third parties may use Advertising Cookies to help gather information about your browsing activity so that they can deliver website advertising to you that is relevant to your interests. The advertising industries in the EU have developed a scheme to help you opt-out of receiving cookies used for these purposes. You can find out more about the EU scheme from www.youronlinechoices.eu. You should check the third party’s website for more information about how they use cookies. The Third-party cookies on our websites are provided by PerimeterX, Mouser, Maxmind, Tealium, Hotjar, Google Analytics (USA and Asia websites) and Adobe Analytics.
• Mobile devices: If you enter our website via mobile device with activated location-based services, we may collect information about your current location as well as the kind of mobile device in use. Most of the mobile devices provide the possibility to disconnect from location-based services or to deactivate those.
• How can you manage cookies from your side? If you would prefer not to accept cookies, most browsers will 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. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. 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. You can find out more information about how to change your browser cookie settings at www.allaboutcookies.org. Do not track signals will be honored only for visitors on www.ttieurope.com.

• Interest-Based Advertising. We participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your browsing history. We share or we permit Google Analytics, Adobe Analytics, LinkedIn, and Tealium to collect information about your use of our website over time so that they may play or display ads on our Service, on other devices you may use, and on other websites, apps, or services, including on Facebook. The information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the site, whether you log in to your account on our Services, or otherwise engage with us. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.  The following contains additional information on these third-parties:
• We use Google Analytics to help us measure traffic and usage trends regarding the application webpages and to understand more about the demographics of our users.  On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage to us.On ttieurope.com we have also added the code “anonymizeIP” to Google Analytics on this website. This masks your IP address so that all data is generally collected anonymously.We also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google AdWords. These features enable us to use first-party cookies and third-party cookies together to inform, optimize, and display ads based on your past visits to the Service.For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
• We use Google Analytics to help us measure traffic and usage trends regarding the application webpages and to understand more about the demographics of our users.  On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide other services relating to website activity and internet usage to us.On ttieurope.com we have also added the code “anonymizeIP” to Google Analytics on this website. This masks your IP address so that all data is generally collected anonymously.We also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google AdWords. These features enable us to use first-party cookies and third-party cookies together to inform, optimize, and display ads based on your past visits to the Service.For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
• We use Adobe Analytics, a web analytics service provided by Adobe Systems Software to help us to analyze overall traffic patterns through our website. By transmitting the information generated by the cookie about your use of the website to Adobe, technical settings ensure that your IP address is anonymized before geolocalization takes place on ttieurope.com and will be replaced by a generic IP address before storage. On behalf of the website provider, Adobe will use this information for the evaluation of your use of the website, compiling reports on website activity for website operators, and in order to provide other services relating to website activity and use of the Internet to the website provider. Adobe will not associate your IP address with any other data held by Adobe. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do, you may not be able to use the full functionality of the website. Furthermore, you can prevent Adobe’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available under LINK http://www.adobe.com/privacy/opt-out.html.
• We use Tealium AudienceStream on ttiinc.com, an analysis software of Tealium Inc., to measure and to evaluate the usage behavior (clicks, mouse movements, scroll heights, etc.) on our website. In order to do so, Tealium collects data on our website, from which user profiles can be created by using pseudonyms. Tealium particularly analyses rather technical information, such as device information or mouse movement. We use this information to customize parts of our website to better meet your needs. The pseudonymized user profiles are not combined with personal data about the bearer of the pseudonym unless the data subject has given his explicit consent to do so. The IP address transmitted by your browser is also not merged with the user profiles. You can prevent Tealium from collecting the data by clicking on the following link and following its instructions: https://tealium.com/preferences/.
• We use LinkedIn Conversion Tracking and Insight Tag on ttiinc.com a piece of lightweight JavaScript code that we have added to our websites to enable in-depth campaign reporting and to help us unlock valuable insights about our website visitors.  We use the LinkedIn Insight Tag to track conversions, retarget website visitors, and unlock additional insights about customers interacting with our LinkedIn adverts.  The LinkedIn Insight Tag enables the collection of metadata such as IP address information, timestamp, and events such as page views.  All data is encrypted.  The LinkedIn browser cookie is stored in a visitor’s browser until they delete the cookie or the cookie expires (there is a rolling six-month expiration from the last time the visitor’s browser loaded the Insight Tag). You can opt-out of cookies from LinkedIn on your LinkedIn settings page and we recommend you read their Cookie Policy for more information
• Social Media Widgets and Advertising. Our websites include social media features, such as the Facebook Like button, Google Plus, LinkedIn, Twitter and YouTube. These social media companies may recognize you and collect information about your visit to our Service, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.We display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Service while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.
• Cross-Device Linking. We or our third-party partners Google Analytics, Adobe Analytics, Tealium and Hotjar may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. Our third-party partners employ tracking technologies or the application of statistical modeling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as a cookie id) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.

Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices and/or the DAA’s resources at www.aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.

Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all interest – based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

California Privacy Rights:The California Consumer Privacy Act of 2018 (CCPA) requires businesses like ours to provide certain information. We fully describe our practices to all our members and visitors in this Privacy Policy but use this separate section to ensure that we meet the CCPA’s requirements.

TTI, Inc does not sell your personal information. We only share your information as described in this Policy.

You have the right to request from us the following information about your personal information we have collected during the past 12 months:

• the categories and specific pieces of personal information we have collected about you;
• the categories of sources from which we collected the personal information;
• the business or commercial purpose for which we collected the personal information;
• the categories of third parties with whom we shared the personal information; and
• the categories of personal information about you that we disclosed for a business purpose

In addition, you have the right to request that we delete the personal information we have collected from you.
This request can be made twice in a 12-month period.

How we will verify your request:

We will match at least two data points that you provide with your request, or in response to our request for verification information, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity.  Examples of relevant data points may include your name and email address, your zip code or information about products or services that you have purchased from us.

To submit a request, please send an email to privacy@ttiinc.com or send a letter addressed to:
TTI Privacy
2441 Northeast Pkwy
Fort Worth, TX USA
76106-1816

We will not discriminate against you for exercising any of your CCPA rights.

Unless permitted by the CCPA, we will not:

• Deny you Services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We do not knowingly collect or solicit any information from anyone under the age of 13 on this Service. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at privacy@ttiinc.com.

From children under the age of 16 residing in the EU, we will not process any personal information on the ground of a consent.

The Service 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, and share information. We are not responsible for the privacy practices or the content on the websites of third-party sites.

We may make changes to Privacy Policy from time to time. Please review our policies regularly, as updated policies will apply to your future use of our Services.