Websites (“Sites”) and applications (“Apps”) made available by T&G Global Limited and/or one or more of its subsidiaries or affiliates (individually and collectively, “T&G”, “we”, “us” or “our”) are controlled and/or maintained by T&G.
At T&G, we recognize concerns about the information you provided to us and how we treat that information. T&G respects your privacy and is committed to protecting the Personal Information that it collects by taking appropriate measures to ensure the accuracy, integrity and security of such information and to only permit appropriate access to it, in accordance with relevant laws and regulations, including (where applicable) the EU General Data Protection Regulation (EU GDPR).
- Is information that relates to living individuals and which can be identified from the data or from other information which is in the possession of, or likely to become into the possession of T&G;
- Does not include data concerning a company, a partnership or an association;
- Need not to be sensitive or secret to require protection under this policy.
Our promise to you:
- When we need your Personal Information we always explain the purpose(s) for which it is collected and we will not use your Personal Information for any other purpose(s) without asking you first;
- We do not retain your Personal Information longer than is required for the purpose(s) for which it is collected;
- Your Personal Information will only be accessible by persons we authorise to access it;
- You can ask to review or update the Personal Information that we hold about you;
- Unless required by law or regulation, we will only share your Personal Information with third parties in accordance with the purpose(s) for which it was collected or otherwise with your explicit consent;
- We will use all reasonable endeavours when selecting and engaging third parties with whom we will disclose your Personal Information and we will hold them accountable to the same data protection and privacy standards we meet ourselves;
- We will actively monitor external threats and will endeavour to act quickly and transparently to protect your Personal Information;
- We understand that technology develops rapidly and we will continuously monitor and enhance the measures we have implemented to protect your Personal Information from unauthorized and accidental loss or disclosure.
Your Personal Information and How We Use It
We respect the privacy of all our online guests. Our Sites, Apps and underlying infrastructure recognize and record certain information about visitors and users. The nature of the information collected may include the type of browser used, the type of operating system of your computer or other Internet access device, the domain name or Internet Protocol (“IP”) address of the visitor’s / user’s Internet service provider, the Site/App pages visited by users, the actions taken on said pages, and the character and duration of Site/App usage. In addition, our Apps will recognize and record all data that you input into it.
In the instance where users provide additional Personal Information during their use of the Site or App (for example by logging in), this Personal Information may be stored alongside the aforementioned information and all subsequently collected information. This information (both personally identifiable and non-personally identifiable) may be used for the purposes of improving our Sites and Apps, improving our business, troubleshooting issues, supporting our customers/users and any other use that we deem necessary for the effective delivery of services to our end-users and our customers. The collection of information for these purposes may be facilitated by our Apps and Sites directly or by using external third-party services including, but not limited to: Google Universal Analytics, Mixpanel Analytics, Session Recording Tools, etc.
Non-Personal Information gathered by our Sites during regular browsing (i.e. not signed in) may be used to help analyse Site traffic and improve our services. We may also aggregate such information to create statistical data and we may share that information (or its non-aggregated form) with potential advertisers, partners, affiliates and other third parties. At no point, however, do we access any personally identifiable facts in this process. We do not collect personally identifiable information from visitors to our Sites or users of our Apps unless it is provided to us voluntarily and knowingly.
How We Safeguard your Personal Information
T&G has and will endeavour to maintain the appropriate technical and organisational measures to protect Personal Information against accidental or unlawful damage or destruction, accidental loss, theft, alteration, unauthorised disclosure, access or use. We endeavour to provide a level of security appropriate to the risk represented by the nature of Personal Information being protected and purpose(s) for which it is being collected.
Personal Information may only be accessed by T&G employees, contractors and agents on a need-to-know basis, for the purpose(s) for which the Personal Information has been collected and only in support of legitimate business purposes.
Please be advised, however, that while we strive to do everything reasonably possible to protect your Personal Information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us and cannot be responsible for the theft, destruction, or inadvertent disclosure of your Personal Information where our security measures have been breached. Consider this when making your Personal information available to us.
Who We Might Share Personal Information With
We will not sell your Personal Information and the operation of our business does not rely on such action. Your Personal Information may be transferred to other companies within T&G’s group of companies, or other third-parties that help us deliver our services to you. These companies might be located in other countries and may be subject to different laws.
We will not share your Personal Information with third parties unless one of the following conditions or reasons apply:
- You have provided your consent. We will ask for your consent before sharing any of your Personal Information. You are entitled to withdraw your consent at any time.
- For external processing. We may provide your Personal Information to other companies within the T&G group of companies or to other trusted business partners who process data for us or provide services on our behalf. They will only be entitled to use the Personal Information in accordance with our instructions and, at all times, in compliance with all relevant Data Protection Legislation.
- For legal purposes; We may transfer your Personal Information to Government authorities as required or allowed to by applicable law.
- Further Disclosures: We reserve the right to disclose any Personal Information if we reasonably believe that such action is necessary to protect or defend the legal rights or property of T&G, our Sites or Apps and the users of them; or in an emergency to protect the health and safety of our Site’s or App’s users or the general public.
You have the option of deciding whether or not to accept a cookie by resetting your browser to notify you whenever a cookie is being sent to your hard drive. You may also delete a cookie manually from your hard drive. Please note, however, that some parts of our Sites or use of our Apps may not function properly or may be considerably slower if you refuse to accept a cookie or choose to disable your cookies settings.
Transfer of Assets
As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, Personal Information, non-Personal Information, and any other information that we have collected about the users of our Sites and Apps may be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.
Last updated: January 2022
Under the CCPA, “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked directly or indirectly with a particular California Consumer or household. Personal Information does not include certain types of information, including, for example:
- Publicly available information from government records.
- Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to a California Consumer.
- Personal information relating to our job applicants, employees, officers, directors, or contractors; or
- Personal information relating to an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, non-profit, or government agency that is doing business with us.
Collection of Personal Information
We collect Personal Information through every communication and interaction with you. This includes, without limitation, through our website and when you otherwise communicate with us by telephone, mail, email, or social media. You may provide us with your Personal Information by filling in forms on our Website or corresponding with us in any other way. When you interact with our website, we may also use automated technologies or interactions to automatically collect technical data about your electronic devices and browsing actions and patterns. We collect this Personal Information by using cookies, server logs and similar technologies.
Personal Information We Collect
- We collect your name, telephone numbers, email address, and contact address when you complete online forms, opt-in to receive marketing messages, respond to our marketing inquiries or surveys, send us emails or other messages, contact us about a product, submit recipes to us, or enter into a drawing or contest sponsored by us.
- We collect your IP address automatically when you access our website.
- We collect your mobile or other device ID automatically when you access our website.
- Financial Information: We do not collect financial information about you, such as your banking, credit card or debit card information.
- Protected Classifications: We may collect information directly from you about your protected classifications under California or United States law, such as your age, gender, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, veteran or military status, and genetic information.
- Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, as well as purchasing or consuming histories or tendencies.
- Biometric Information: We may collect your image or voice recording if you provide photographs, videos or audio files to us, and may collect a voice recording if you telephone us. We otherwise do not collect information about your physiological, biological, or behavioral characteristics.
- Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, and information regarding your interaction with product portals, websites, applications, or advertisements automatically when you use our website or mobile apps.
- Geolocation Data: As described above, we collect your IP address automatically when you use our website. We may be able to determine your general location based on the IP address.
- Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We also may collect audio or visual information about you through our security systems if you visit or offices. We do not collect any thermal, olfactory, or similar information.
- Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile.
Categories of Sources of Personal Information
In the 12 months since this California Policy was “Last Updated” as stated above, we have collected personal information relating to California Consumers from the following sources:
- Directly from you, the California Consumer
- Automatically when you use our website or mobile apps
- Our subsidiaries and other affiliates
- Business partners
- Marketing vendors
- Survey services
- Service providers, such as website hosting services, commercial research services, payments processors and information processors
- Third parties you have authorized or directed to share information with us
- Government entities from which public records are obtained
The Business or Commercial Purposes for Which We Collect Personal Information
We use personal information relating to California Consumers to operate, manage and maintain our business, to provide our products and services, and to accomplish out business purposes and objectives, including the following:
- Marketing our services and products, and the products of our business partners, to you
- Conducting surveys and market studies
- Delivering relevant website content and advertisements to you and measuring or understanding the effectiveness of the advertising we provide to you
- Offering and conducting sweepstakes, contests and similar events
- Responding to your emails, messages or other inquiries to us
- Administering and protecting our business, our website and our mobile apps, including through troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data
- Debugging to identify and repair errors that impair existing intended functionality
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity
- Auditing related to a current interaction and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
- As otherwise disclosed to you at or before the point of collecting your personal information
Disclosure of Personal Information to Third Parties
In the 12 months since this California Policy was “Last Updated” as stated above, we have disclosed each of the above categories of personal information for our business purposes to one or more of the following categories of third parties:
- Our subsidiaries and other affiliates
- Service providers, such as commercial research services, payments processors and information processors
- Business partners that perform marketing services on our behalf
- Third parties with who you authorize or direct us to share your information
- Government entities and others with whom we share information for legal or necessary purposes
Sales of Personal Information
In the past 12 months since this Policy was Last Updated, we have not sold Personal Information that is subject to the CCPA, including the Personal Information of individuals under 16 years of age. For purposes of this Privacy Notice, “sold” means the disclosure of Personal Information to a third party for monetary or other valuable consideration. We do not share Personal Information with any third parties for their marketing purposes.
Your Rights Under the CCPA
Each California Consumer has rights to know about, obtain copies of and delete their personal information. The following describes those rights.
Your Right to Know About Your Personal Information
You have the right to request that we disclose to you the following information covering the 12 months prior to your request (“Requests to Know”):
- The categories of Personal Information that we collected about you;
- The categories of sources from which we collected your Personal Information;
- The categories of Personal Information that we have sold or disclosed for a business purpose;
- Our business or commercial purposes for collecting or selling your Personal Information;
- The categories of third parties to which we disclosed or sold your Personal Information for a business purpose. As noted above, we do not sell your Personal Information; and
- The specific pieces of Personal Information that we have collected about you (you have the right to copies of those specific pieces of Personal Information).
Your Right to the Deletion of Your Personal Information
You also may request that we delete (and direct our service providers to delete) the Personal Information that we have collected about you (“Requests to Delete”). In some cases, however, the CCPA provides for exceptions to this right to have your Personal Information deleted, such as if the Personal Information is need to provide a service you requested or if the information is needed for us to comply with a legal obligation. If we deny your Request to Delete your Personal Information, we will tell you the reason or reasons for that denial.
How to Submit Requests to Know or Requests to Delete
You may make Requests to Know or Requests to Delete by any of these methods:
- Emailing us at email@example.com
- Fill out the Contact Us form here: https://envyapple.com/us/contact/
For individuals submitting a Request to Know or Request to Delete on behalf of another person, we may require proof of authorization and verification of identity directly fro the person for whom the request is made. For a company or organization submitting a request on behalf of another person, we may require proof of authorization, such as a power of attorney and verification of identity, directly from the person for whom the request is made.
If you submit a request in a manner that is not one of the designated methods of submission, we will either treat your request as if it had been submitted in accordance with these designated methods or provide you with specific directions on how to submit the request or remedy the deficiencies in your request, if any.
How We Verify and Process Your Information Right Requests
Upon receiving your Request to Know or Request to Delete, we will confirm receipt of your request within 10 days and provide information about how we will process your requests.
We will respond to your request within 45 days barring any unforeseen complications. If we are unable to verify your identity or if other complications arise, we may take up to 90 days to process your request or may in some cases deny your request, but we will in such cases notify you and provide an explanation.
To process your request, we will ask you for information that allows us to verify your identity and we will use that information only for that purpose. The information we request and the degree of verification you will need to provide will depend on the scope of your request. Requests for copies of specific pieces of your Personal Information may require additional information to verify your identity as compared to general Requests to Know. The information that we will need to verify your identity for Requests to Delete will depend on the nature of your request. For example, we may require a reasonably high degree of certainty for verification of a request to delete documents; by contrast, we may require only a reasonable degree of certainty for a request to delete browsing history.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify you identity or cannot verify that a person claiming to be your agent has the authority to make the request on your behalf.
If there is no reasonable method by which we can verify your identity to the degrees of certainty as described above, we will state so in response to your request and explain why we have no reasonable method by which we can verify your identity. We generally will avoid requesting additional information from you for purposes of verification. If we do request additional information from you, it shall only be used for the purposes of (1) verifying your identity while you are seeking to exercise your rights under the CCPA; and (2) for security or fraud-prevention purposes. We will delete any new personal information collected for the purposes of verification as soon as practical after processing your request, except as otherwise required by law.
In addition, we will not honor your request where an exception under the California law applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another California consumer or where the Personal Information we have about you is not subject to the CCPA’s access or deletion rights. We also will advise you in our response if we are not able to honor your request for these reasons.
Your Right to Be Free From Discrimination
You have the right to be free from discrimination for exercising your rights under the CCPA.
California “Shine the Light” Disclosures
California Civil Code Section 1798.83 permits California Consumers to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such request, please email us at firstname.lastname@example.org.
Contact for More Information
If you have any questions or concerns about our privacy policies and practices, please email us at email@example.com.