Privacy Policy

PRIVACY
Your privacy is important to TGI Connect. This Privacy Policy explains how TGI Connect collects, uses, discloses, and retains your information.

WHO IS TGI CONNECT?
This Privacy Statement describes the privacy practices of TGI Connect (“TGI”) for data that we collect:

• through websites operated by us from which you are accessing this Privacy Statement, including tgi-connect.com and other websites owned or controlled by TGI (collectively, the “Websites”)
• through the software applications made available by us for use on or through computers and mobile devices (the “Apps”)
• through our social media pages that we control from which you are accessing this Privacy Statement (collectively, our “Social Media Pages”)
• through HTML-formatted email messages that we send you that link to this Privacy Statement and through your communications with us
• when you visit our offices, or through other offline interactions

Collectively, we refer to the Websites, the Apps and our Social Media Pages, as the “Online Services” and, together with offline channels, the “Services.” By using the Services, you agree to the terms and conditions of this Privacy Statement.

YOUR CONSENT
It is important to us that where we collect, use or disclose your personal information, we have your consent to do so.

When you use the TGI online services, you may encounter touchpoints throughout your journey where personal information may be requested.

If you choose to provide TGI with your personal information, you acknowledge and consent to TGI’s collection, use, disclosure, and retention of your personal information in accordance with this Privacy Policy and as otherwise permitted by applicable law.

Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, when you accept our products or services, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your acceptance and use of those products or services, or for other purposes identified to you at the relevant time.

Typically, we will seek your consent at the time that we collect the personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this Privacy Policy or separately), we will endeavor to advise you of that purpose before such use or disclosure.

As we have described above, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.

PERSONAL INFORMATION
Personal information is any information about an identifiable individual, other than the person’s business title or business contact information when used or disclosed for the purpose of business communications. Personal information does not include anonymous or non-personal information (i.e., information that cannot be associated with or tracked back to a specific individual).

HOW TGI COLLECTS YOUR PERSONAL INFORMATION
In strict adherence with government regulations, PIPEDA and CASL, TGI may collect and add current and past customer data from our systems business systems to our email subscriptions lists and request your consent (opt-in) to receive product updates, news, special offers and promotions by email.

You may be asked to voluntarily provide personal information to TGI any time you are in contact with TGI, including contact by telephone or email, through the TGI website, or in person. In those circumstances you can choose not to provide certain requested personal information, but then you may not be able to purchase products or services or access or use certain features of TGI’s website.

For example, when you create or manage an account with TGI, when you register or subscribe for TGI’s newsletters or promotions, participate in TGI’s promotions and when you contact TGI, TGI may collect a variety of your personal information, including your name, date of birth, mailing and shipping addresses, email address, and phone numbers.

You might also provide TGI with the personal information of other persons, such as business associates or co-workers. Please ensure that you have the consent of other persons before you provide their personal information to TGI.

HOW TGI USES YOUR PERSONAL INFORMATION
TGI uses your personal information for various purposes, and as otherwise permitted by law, including: (a) to contact and correspond with you regarding your business or transactions, and your use of TGI’s website, products and services to provide you with customer care services and to provide you with information regarding TGI’s announcements, promotions, upcoming events, new products and special features; (b) to facilitate transactions and process orders and payments for products and services purchased by you (including to remind you of unpurchased items left in your online shopping cart, to contact you regarding billing and payment discrepancies and to validate receipts); (c) to process and respond to your specific suggestions, comments, inquiries, and requests, and to otherwise administer TGI’s relationship with you; (d) to personalize and improve your user experience; (e) to administer and facilitate your participation in contests and promotions; and (f) to develop, deliver, and improve TGI’s products, services, and advertising.

TGI may also develop a confidential profile for you, which will be used to provide services to you and facilitate your transactions with TGI and your use of TGI’s websites and services.

TGI may combine your personal information collected through various sources, including information collected through TGI’s websites and information obtained from other sources.

You may also provide personal information in order to receive email and other communications from TGI. You may unsubscribe from those communications by using the applicable self-service unsubscribe procedure offered by TGI (for example, by clicking an unsubscribe link in an email or adjusting your website user account preferences) or by contacting TGI using the contact information noted below. From time to time, TGI may use your personal information to communicate with you regarding important matters, such as information about your membership, educational program changes, and deadlines; because this information is important, you may not opt out of receiving these communications.

TGI may use personal information to create non-personal information, and TGI may then use, disclose, transfer, and retain the non-personal information in accordance with this Privacy Policy.

NON-PERSONAL INFORMATION
TGI also collects non-personal information – information that is not about an identifiable individual, including personal information that has been aggregated or otherwise anonymized so that it no longer relates to an identifiable individual. For example, TGI websites automatically collect certain non-personal information regarding website users, such as the dates and times they access the website, the browsers, operating systems, and devices they use to access the website, the website pages they access, and the referring and exit website pages.

TGI may use, disclose, transfer, and retain non-personal information for any purpose and in any manner whatsoever.
If non-personal information is combined with personal information, then the non-personal information will be treated as personal information for the purposes of this Privacy Policy.

COOKIES AND OTHER TECHNOLOGIES
TGI’s website, online services, email messages, and advertisements may use “cookies” and other similar technologies, such as web beacons, pixel or gif tags, and action tags. Those technologies collect information that assists TGI to improve products and services, advertising, customer communications, and user experience. TGI treats information collected by cookies and similar technologies as non-personal information, provided that if internet protocol (IP) addresses or other similar identifiers are considered personal information under your local laws then TGI will treat that information as personal information for the purposes of this Privacy Policy.
For example, TGI may use information collected through cookies and similar technologies to recognize the user of TGI’s’ website, track use of the website, offer personalized web page content, information and advertisements, and otherwise facilitate and improve the website experience. You may choose to decline or disable cookies if your web browser permits, but doing so may affect your ability to access or use certain features of TGI’s website.

TGI may use web beacons, pixel or gif tags, and action tags to confirm that email messages have been delivered and opened. You may opt-out of receiving emails in accordance with this Privacy Policy.

LOCATION-BASED SERVICES
TGI may provide location-based services, including marketing and promotions specific to your location. To do so, TGI collects (directly or from other service providers) and uses information regarding the geographic location of your devices. If the location data contains your personal information, then TGI will treat the location data as personal information in accordance with this Privacy Policy. If the location data is collected anonymously in a form that does not personally identify you, then TGI will treat the location data as non-personal information in accordance with this Privacy Policy, provided that if the location data is considered personal information under your local laws then TGI will treat that data as personal information for the purposes of this Privacy Policy.

SOCIAL NETWORKING AND SIMILAR SITUATIONS
When you use certain aspects of TGI’s website or other services, or post information to a TGI forum, chatroom, or other social networking service (such as TGI’s Facebook, Twitter, Instagram or LinkedIn pages) the personal information that you post or share is visible to other persons and can be read, collected, used, and disclosed by other persons, including to send unsolicited messages. You are solely responsible for the personal information that you choose to post or share in those situations. TGI has no control over, responsibility or liability for, the use, disclosure, and retention of the personal information that you disclose in those situations, and the use, disclosure, and retention disclosure of the disclosed information is not subject to this Privacy Policy. Please be careful when disclosing your personal information in those situations.

DISCLOSURE OF PERSONAL INFORMATION
Affiliates – TGI and its affiliates may share your personal information with each other and use it in accordance with this Privacy Policy.

Joint Promotions – Certain promotions or services may be offered jointly by TGI and other companies or organizations, and in those circumstances your personal information collected in connection with those promotions and services will be shared by TGI and the other companies and organizations involved. TGI has no control over, responsibility or liability for, the use, disclosure, and retention of personal information by the other companies or organizations; their use, disclosure and retention of your personal information is governed by the privacy policies of those other companies (not this Privacy Policy).

Suppliers and Service Providers – TGI may disclose your personal information to TGI’s suppliers and service providers to provide products and services to TGI (including to conduct customer research and satisfaction surveys and to provide customer communications, data processing and data management, marketing, fraud detection, address validation, and tax services) to assist TGI to use your personal information in accordance with this Privacy Policy (including to process your transactions and payments, fulfill your orders, deliver products to you, provide customer service) and as otherwise permitted by law.

For example, TGI engages service providers to help operate TGI’s websites, advertising, and email services and to analyze information collected through websites, advertising, and email (including through cookies and other similar technologies).

TGI requires its suppliers and service providers to agree to use your personal information only for the purposes for which it is provided to them, and to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy.

Others – TGI may disclose your personal information as required by legal disclosure obligations under applicable law, including to comply with a subpoena, warrant or court or arbitral order, or litigation disclosure obligations. TGI may also disclose your personal information if TGI reasonably believes disclosure is necessary or appropriate in connection with national security, law enforcement or other issues of public importance. TGI may also disclose your personal information as otherwise required or authorized by law or if TGI reasonably believes the disclosure is necessary or appropriate to protect and enforce TGI’s legal rights, interests, and remedies or protect the business, operations or customers of TGI or other persons (including detecting and preventing fraud). TGI has no control over, or responsibility or liability for, the use, disclosure, and retention of your personal information disclosed in those circumstances, and use, disclosure and retention of the disclosed information is not subject to this Privacy Policy.

For example, TGI may disclose information to law enforcement authorities or other businesses and organizations in connection with the detection, prevention, and prosecution of activities that TGI reasonably believes to be unlawful or fraudulent, and the disclosed information may include personal information of the individuals suspected of involvement in unlawful or fraudulent activities.

TGI may disclose your personal information in connection with a proposed or actual business transaction, such as a corporate reorganization, merger or acquisition or the sale of some or all of TGI’s business or assets, but TGI will require that the information recipient agree to protect the privacy of your personal information in a manner that is consistent with this Privacy Policy and applicable law.

RETENTION, LOCATION AND PROTECTION OF PERSONAL INFORMATION
TGI retains your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy or such longer retention period as may be required or permitted by applicable law. TGI will store and process your personal information only in Canada. TGI employs reasonable safeguards – including administrative, technical, and physical measures – appropriate to the sensitivity of the personal information in its possession or under its control in order to protect that information from unauthorized access, collection, use, disclosure, disposal, or similar risks. However, TGI does not warrant or guarantee the security of its servers. Further, TGI cannot provide assurance that your personal information will be save and not interception in the course of transmission over the internet. Transmission of your information is at your own risk.

ACCURACY AND ACCESS TO PERSONAL INFORMATION
You can help TGI maintain the accuracy and completeness of your information (including your TGI website account information) by notifying TGI of any changes to your personal information. You may update your TGI website account information through TGI’s website.

You may request access to your personal information and information about TGI’s collection, use, disclosure, and retention of that information by sending your request to TGI at the address noted below. Subject to applicable exceptions and limitations prescribed by law, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate.

OTHER MATTERS
Business Contact Information – To the extent permitted by law, the provisions of this Privacy Policy concerning personal information do not apply to information (such as your name, position or title, business address, business telephone number, business fax number, and business email address) that enable you to be contacted at a place of business.

Personal Information of Children – TGI does not knowingly collect personal information from or relating to children who are under 13 years of age without the consent of the child’s parent or legal guardian. TGI expects parents to supervise and monitor their children’s disclosure of personal information, including throughTGI’s website. Please immediately contact TGI at the address noted below if you believe that TGI has unintentionally collected personal information from a child under 13 years of age without the consent of the child’s parent or legal guardian. If TGI learns that it has inadvertently collected the personal information of a child under 13 years of age without appropriate consent, TGI will use reasonable efforts to delete that information from its systems (except to the extent that retention of the personal information is required or permitted by applicable law).

Employment – TGI may use and disclose your personal information to administer and process your application for employment with TGI and related matters.

Other Websites/Online Services – TGI’s website and online services may contain links to other websites or online services. When you use those links, you are contacting another website or service. TGI has no responsibility or liability for, or control over, those other websites or service or their collection, use, disclosure, and retention of your personal information. Please refer to the privacy policies and terms of use that apply to those other websites or online services.

Policy Changes – TGI may change this Privacy Policy from time to time by posting a new version of this Privacy Policy on TGI’ website at www.tgi-connect.com. TGI’s collection, use, disclosure and retention of your personal information will be governed by the version of this Privacy Policy in effect at that time. Your continued dealings with TGI subsequent to any changes to this Privacy Policy will signify your consent to the collection, use, disclosure, and retention of your personal information in accordance with the changed Privacy Policy. Accordingly, you should check the “last updated” date of this Privacy Policy (at the bottom of the page) and review any changes since the last version.

Unsubscribing to Newsletters and Messages – You may unsubscribe from TGI’s electronic newsletters and similar messages by using the applicable self-service unsubscribe procedure (for example, by clicking an unsubscribe link in an email or adjusting your website user account preferences), or by contacting TGI at info@tgi-cinnect.com .
Contacting TGI’s Privacy Officer – If you have any comments or questions about this Privacy Policy or your personal information, please contact TGI’s Privacy Officer by mail or email at: TGI Connect – Privacy Officer, 905 Queenston Road, Stoney Creek, ON L8G 1B6, Canada , email: info@tgi-connect.com.

English Language – You and TGI have each expressly requested and required that this Privacy Policy and all other related documents be drawn up in the English language. Les parties conviennent et exigent expressement que ce Politique et tous les documents qui s’y rapportent soient rédigés en anglais. Last updated: August 30, 2017.