Privacy Policy

 

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Last Updated July 14, 2018

The Teo Group Company and its wholly and majority-owned entities (collectively, the “Teo Group”), respect your concerns about privacy. References in this Privacy Policy to “Teo”, “we”, “us”, and “our” are references to the entity responsible for the processing of your personal information, which generally is the entity that obtains your personal information.

This Privacy Policy applies to the personal information we obtain through the Teo Group’s properties, including websites, mobile applications and social media pages that reference this Privacy Policy (“Online Channels”); offline collection in connection with sales, marketing, partner and supplier engagement (“Offline Channels”); and third-party sources, including ad networks and lead brokers (collectively, the “Channels”). This Privacy Policy does not apply to personal information obtained through our Careers webpage, which is subject to the Candidate Privacy Notice, or to products and services that post separate privacy policies.

This Privacy Policy describes the types of personal information we obtain through the Channels, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of the information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

The Online Channels may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by the Teo Group. We are not responsible for the privacy practices of third parties, which are subject to their respective privacy policies.

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  • Personal Information We Obtain

 

 

 

 

 

 

 

 

 

 

 

Personal Information We Obtain

We may obtain personal information through the Channels. The types of personal information we may obtain include:

  • contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
  • information used to create your online account (such as username, password and security question and answer);
  • biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
  • purchase and customer service history;
  • financial information (such as payment information, including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score);
  • location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
  • contact information you provide about friends or other people you would like us to contact;
  • clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies (see our Cookie Consent Tool); and
  • other personal information contained in content you submit to us (such as through our feature).

In addition, in connection with our insurance and financial services products, we may obtain government-issued ID numbers and Tax ID numbers, such as National Insurance and US Social Security numbers.

We can also use third-party web analytics services in connection with the Online Channels such as Google Analytics, Adobe Analytics and Marketo, which use cookies and similar technologies to collect data (such as IP addresses) to evaluate use of and interaction with the Online Channels. (You may learn about Google’s advertising features, including Google Analytics’ currently available opt-out mechanisms, here. To learn more about these and other analytics services and how to opt out, please view our Cookie Consent Tool here.)

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

Cookies and Similar Technologies

The Teo Group uses cookies, web beacons and similar technologies on our Online Channels. You may learn more about these technologies in our Cookie Consent Tool. To view the list of Teo Group and third-party cookies used on the Online Channels and to make choices about those cookies, please visit our Cookie Consent Tool here.

How We Use Personal Information

We may use the personal information we obtain to:

  • provide and administer our products and services;
  • process and fulfill orders and keep you informed about the status of your order;
  • communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
  • conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
  • perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
  • engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
  • provide customer support;
  • process, evaluate and respond to requests, inquiries and applications;
  • create, administer and communicate with you about your account (including any purchases and payments);
  • administer and register participants in our courses;
  • provide investor services;
  • conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
  • operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
  • verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
  • conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Online Channels terms of use); and
  • maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.

We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

The legal basis for Teo Group processing your personal information as described above will typically be one of the following:

  • Your consent;
  • Performance of a contract with you or a relevant party;
  • Our legitimate business interests; or
  • Compliance with our legal obligations.

Personal Information Sharing

We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.

  • We may share personal information within the Teo Group for the purposes described in this Privacy Policy.
  • We may share personal information with service providers we have retained to perform services on our behalf (such as payment processing, order fulfillment, customer support and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements.
  • We may share personal information with our joint marketing partners and other business partners for the purposes described in this Privacy Policy.
  • We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
  • We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as the Teo Group provides with respect to the information we share.

Data Transfers

We may transfer the personal information we collect through the Channels to, and store such data in, other countries, including the U.K. Europe and U.S., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information. The Teo Group has entered into Binding Corporate Rules governing our handling of personal information of residents of the European Union. For further information about the Teo Group’s Binding Corporate Rules, please click here.

Your Choices

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, limit the communications you receive from us or submit a request, please contact us as specified in the How To Contact Us section of this Privacy Policy.

You also may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising. To learn how to opt out of ad network interest-based advertising in the United States, please visit Digital Advertising Alliance, the Network Advertising Initiative, and TrustArc.  In the European Union, please visit European Interactive Digital Advertising Alliance or TrustArc. The Online Channels are not designed to respond to “do not track” signals received from web browsers.

To the extent provided by the law of your jurisdiction, you may have the right to (1) access certain personal information we maintain about you; (2) request that we update, correct, amend, erase or restrict your personal information; or (3) exercise your right to data portability. Where provided by law, you may withdraw consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward as appropriate. To request to exercise these rights, please contact us as indicated in the How To Contact Us section of this Privacy Policy. For more information, please see the “Individual Rights” section of our Binding Corporate Rules here. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response.

How We Protect Personal Information Transmission

We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.

Retention of Personal Information

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

Additional Information

Children’s Personal Information

The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the How To Contact Us section of this Privacy Policy.

Changes to Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us by visiting our Feedback & Inquiries Form or write to us at: