Abiding by the Law; Right to Disclose
Privacy Policy - EU
Your Privacy, Our Policy.
Read Our Privacy Policy to Understand How we Protect your Data, Ensuring your Personal Information Remains Confidential and Secure.
Your Privacy, Our Policy.
Read Our Privacy Policy to Understand How we Protect your Data, Ensuring your Personal Information Remains Confidential and Secure.
EU – U.S. PRIVACY – SHIELD FRAMEWORK PRIVACY POLICY, AND COOKIES AND SIMILAR TECHNOLOGIES STATEMENT
*Effective June 30, 2020
Tollanis Solutions, Inc. (hereinafter, “Tollanis,” “we,” “our,” and “us”) is committed to safeguarding privacy. This Privacy Policy (this “Policy”) is published to help Individuals (as defined below) understand the measures we take to protect privacy and how such measures can help Individuals to protect privacy.
Tollanis is an information technologies services corporation headquartered in the United States. It has one wholly owned subsidiary: Tollanis Solutions LLP., an Indian limited liability partnership. The Tollanis Companies (as defined below) share some databases, technological systems, business processes, and management structure, which may result in the transfer of some information across borders. In addition, Tollanis, by itself or through its subsidiaries, may provide customer services that involve the Processing of Personal Data (as such terms are defined below), and such Processing may also result in the transfer of some information across borders.
Tollanis is committed to, participate in, relies upon, and complies with the EU-U.S. Privacy Shield Framework (the “Framework”) as set forth by the U.S. Department of Commerce. The U.S. Department of Commerce’s International Trade Administration (ITA) continues to administer the Privacy Shield program despite the Schrems II judgment. With respect to the collection, use, and retention of Personal Data (as defined below) received from the European Union (“EU”) in the United States (“US”), Tollanis complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom, as applicable, to the United States in reliance on Privacy Shield. Tollanis has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity; Access, and Recourse, Enforcement; and Liability (hereinafter, the “Principles”) with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
For the purposes of the Framework, Tollanis is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
This Policy applies to all Personal Data (as defined below) described in this Policy that is collected and transferred by or on behalf of Tollanis Companies, or its customers, prospects, partners, vendors, or suppliers from countries in the EU to Tollanis in the U.S. This Policy also addresses the collection and use of Personal Data gathered in connection with the Site.
Capitalized terms are defined as set out below, or as otherwise defined throughout this Policy.
Typically, we collect and receive two types of Personal Data: Business Contact Data and HR Data. When we receive such Personal Data, we will use and disclose it only in accordance with the notices provided and the choices, as applicable, made by the Individual to whom such Personal Data relates.
We must disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We do not sell, lease, or rent Personal Data to third parties.
Typically, Business Contact Data consists of names, business titles, and contact information, such as email addresses, telephone numbers, fax numbers, and business and mailing addresses. Business Contact Data may also consist of certain identification information, such as a user ID or code, and may include information related to, as applicable, service requests, including location and equipment. Business Contact Data is collected when such Data is voluntarily provided to us by an individual or in connection with a potential or existing business relationship. We collect, Process, and use Business Contact Data for the following purposes:
Typically, HR Data consists of name, title, contact information, addresses, telephone numbers, fax numbers, email addresses, personal, employee, and/or tax identification number(s), job descriptions, performance evaluations, resume, qualifications, accolades, disciplinary actions, salary history and information, picture/photo, and Sensitive Data that may relate to an employee’s health or other sensitive matters, such as information pertaining to an employee’s dependents and family members. Tollanis collects, uses, and Processes HR Data only for the following purposes:
EU employees are notified in detail regarding how their HR Data will be Processed and used at the time of their employment. Before using an EU employee’s HR Data for any purpose other than described above, affirmative consent from such employee will be obtained. Such consent may be declined or withdrawn at any time; provided, however, that HR Data will be retained in the manner and for the time periods required under applicable laws and regulations.
HR Data may be accessed by other employees of any Tollanis Company only as necessary for legitimate human resources or business functions or issues. HR Data will be disclosed to third parties only as follows:
EU employees may, for legitimate HR purposes, disclose Personal Data about their family members. In this event, such Personal Data shall be treated in accordance with this Policy as though such Data is HR Data.
Where HR Data is transferred to the U.S. from the EU in the context of an employment relationship, Tollanis will cooperate with investigations by and comply with the advice of the appropriate EU authorities, as applicable.
Generally, an Individual can browse the Site without personally identifying themselves. However, an Individual may choose to provide us with Personal Data by completing a web form that requests any Personal Data; accessing our systems, platforms, and networks; requesting or registering to receive information from us; participating in correspondence or live chats with our representatives; participating in interactive features on the Site; choosing to share a page from the Site through one of our platforms; registering to use social media in conjunction with the Site; entering a contest or promotion sponsored by us; signing up for offerings that are co-sponsored between us and third-parties; reporting any problems or issues with the Site; contacting us; completing our surveys; or otherwise generally submitting Personal Data to us in connection to the Website. We will use your Personal Data only in accordance with the terms of this Policy.
We use cookies and similar technologies in connection with the Site. For more information, please read the COOKIES AND SIMILAR TECHNOLOGIES STATEMENT below.
Tollanis offers each Individual the opportunity to choose whether their Personal Data is
Please note, however, that Tollanis will not provide a “choice” when disclosure is made to an Agent, provided that Tollanis has entered into a contract with such Agent.
For Sensitive Data, Tollanis will request and obtain express consent, otherwise known as an “opt in,” from an Individual if such information is to be
To transfer Personal Data to a third party acting as a Controller, Tollanis will comply with the Notice and Choice Principles. Tollanis will not transfer Personal Data to any third party Controller without entering into a contract with the same that provides that
To transfer Personal Data to a third party acting as an Agent, Tollanis will:
Tollanis will take reasonable and appropriate measures to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into due account the risks involved in the Processing and the nature of the Personal Data. The user must exercise reasonable caution in that, user ID and password/s must not be shared with anyone else, precautions to guard against malware such as viruses, bots, etc. must be taken, suitable anti-virus software/s must be installed and regularly updated, etc.
Tollanis will limit its collection and Processing of Personal Data to only that which is relevant for the purposes set out in the “Notice” section above. Furthermore, we will not Process Personal Data in a way that is incompatible with the purpose(s) for which it has been collected or subsequently authorized by an Individual. We will also take reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current, and will adhere to the principles for as long as Tollanis retains such Personal Data.
Once we’ve collected or Processed Personal Data, we will retain it only for so long as it serves a purpose set out in the “Notice” section above; provided, that, we may retain and Process, subject to the Principles and the EU-U.S. Privacy Shield Framework, Personal Data for longer periods as may be
Tollanis is located primarily in the United States and users understand and agree that any information shared by them specifically with the Site or collected automatically by the Site shall be stored in the USA thereby crossing the international borders of the respective countries and regions.
An Individual may access his or her Personal Data held by Tollanis and correct, amend, or delete such Personal Data where it is inaccurate or has been Processed in violation of the principles, except where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question, or where the rights of persons other than the Individual would be violated.
If you are an Individual and you wish to confirm, correct, amend, or delete your Personal Data, please contact us at [email protected].
In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of Personal Data. Individuals with inquiries or complaints regarding this Policy should first contact Tollanis by emailing us at [email protected]
We will respond to any inquiry or complaint within 45 days of receipt.
There are readily available independent recourse mechanisms to investigate and expeditiously resolve disputes and complaints if a timely acknowledgment of a complaint is not received from us, or if we have not resolved a complaint. The proper independent recourse mechanism to use depends upon the type of Personal Data at issue:
With regard to unresolved Privacy Shield Complaints regarding Business Contact Data, Tollanis has committed to refer those to the American Arbitration Association (AAA)’s International Centre for Dispute Resolution®/AAA Program (the “ICDR/AAA Program”), an alternative dispute resolution provider located in the United States. If timely acknowledgment of a complaint is not received from us, or if we have not resolved a complaint, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint.
The services of ICDR/AAA are provided at no cost to you and by reference to the Principals. Damages may be awarded in accordance with applicable law or private-sector initiatives.
Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any other Privacy Shield mechanisms. Please visit Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
With regard to unresolved Privacy Shield complaints regarding HR Data transferred from the EU in the context of the employment relationship, Tollanis has committed to cooperate with the dispute resolution procedures and the panel established by the EU Data Protection Authorities (DPAs), and to comply with the advice given by the panel.
Tollanis is committed to providing mechanisms for assuring compliance with the Principles. We have procedures to verify that the attestations and assertions we make about our privacy practices are true, and that our privacy practices have been implemented as presented. We routinely perform self-assessments, and may utilize outside assessments, to review our compliance with the Principles.
In cases of onward transfers to third parties, Tollanis has responsibility for the Processing of Personal Data we receive under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf. Tollanis shall remain liable under the Principles if its agent Processes such personal information in a manner that is inconsistent with the Principles, unless Tollanis proves that it is not responsible for the event giving rise to the damage.
We use cookies and other similar technologies in connection with the Site. Those technologies, how we use them, and the choices available related to the same are explained in this Statement. This Statement covers the use of cookies by only this Site and does not cover the use of cookies by any advertisers or third parties.
Cookies are small data files that are written onto an individual computer by a website that stay there unless they expire or are removed. In general, they allow for recognition and make visiting and using a website easier and more efficient. Cookies cannot read data off of a hard drive or read cookie files created by other websites.
Cookies may be “persistent” or “session,” and “first-party” or “third-party.” A persistent cookie remains on a computer or mobile device when it is offline. A session cookie is deleted as soon as a web browser is closed. A first-party cookie is served by the entity that operates the website one is visiting. A third-party cookie is served by an entity other than that which operates the website one is visiting.
All types of cookies are used on the Site. We partner with third-party analytics providers, such as AdWords, AdRoll, and Google Analytics, which set cookies when the site is visited to assist us in understanding our Site visitors, measuring and optimizing the effectiveness of the Site and marketing efforts, advertising, and identifying areas for improvement.
For questions related to the privacy practices and policies of AdWords, AdRoll, or Google Analytics, please refer to their privacy guidelines, notices, policies, and restrictions, which are available at their websites (as applicable). Note that Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions.
Pixels are very small graphics that are loaded when a user visits a website or opens an email. They collect browser and device usage and can set cookies.
HubSpot is a marketing optimization platform that is utilized to market services through the website or via email campaigns. HubSpot is utilized as an online subscription service allowing the Site to build marketing web pages on HubSpot servers. These pages are then utilized for visitors to learn more about the company, download content, and provide their contact information and other demographic information. This information, which is stored and managed on the service providers’ servers, is then used so that the visitors can be contacted about their interest in the Tollanis Companies’ goods or services and interact with us. Information provided may be used by any of the Tollanis Companies and/or HubSpot for marketing and lead generation purposes.
In addition to cookies, as with most websites, our Site gathers certain information automatically and stores it in log files. This information includes Internet Protocol (IP) addresses, traffic data, Internet Service Providers (ISPs), date/time stamps, etc., movements around the Site, other actions taken while visiting the Site, communications data, and whether an email or link sent by a Tollanis Company has been opened.
We may use local storage. Local storage enables data to be stored in a user’s computer or browser, which then reads such data upon the user’s return. It includes HTML5 local storage and browser cache.
We use these technologies to estimate and evaluate the audience size and usage patterns related to the Site, store, and recall information about a visitor’s preferences, speed up searches, authenticate access to and secure various areas of the Site, recognize a computer when the Site is revisited, track responses to our surveys, and conduct marketing and advertising. Ultimately, these uses enable us to compile aggregate data about Site traffic and use, which then allows us to offer better, faster, and safer experiences and content. We may link data collected via these technologies to Personal Data for any of the uses described in this paragraph.
A visitor can manage the above-described uses in several ways.
We reserve the right to amend this Policy at any time and for any reason, including, but not limited to, to address changes or modifications in applicable law(s), the EU-U.S. Privacy Shield Framework, or our business procedures. In the event of any change to this Policy, we will post the revised Policy, with the revision date, to this webpage.
ATTN: Privacy Team
762a South Military Trail
Deerfield Beach, Florida 33442
ATTN: Compliance Officer-US
Office Block 6b-2 at 6th Floor Pavilion
339/2 Mehrauli Road
Gurgaon 122007
