TRANSITION SOLUTIONS INC.
PRIVACY POLICY
Transition Solutions Inc. (“TSI”, “we” or “us”) is committed to protecting and respecting your privacy.
This Policy (together with other documents referred to herein) describes what personal information we collect from you and how we process your personal information when you visit https://transitionsolutions.com/ (the “Website”). This policy also describes the commitment to compliance with the EU-U.S. Privacy Shield Principles as further described below. To learn more about the Privacy Shield and to obtain a copy of the Privacy Shield Principles, please visit https://www.privacyshield.gov
Personal information we may collect from you:
· we will collect personal information on your visits to the Website including, but not limited to, traffic data, location data, weblogs, content from surveys and contact forms and other communication data and the resources that you access. Our collection of this personal information will make your visit to the Website easier in the future as we will be able to suggest Content that is relevant to you based on the location from which you access the Website.
· we will collect any information you provide to us when you use our contact forms (for example “Contact us” or “Subscribe to our newsletter”. The provision of your personal information via our contact forms is not a statutory or contractual requirement; however, please note that fields marked with an asterisk (*) are mandatory fields, because we need this information to comply with or respond to your request. Other information or personal information you share with us when completing our contact forms is in your sole discretion. If you contact us, we will keep a record of that correspondence.
· we use your personal information to send you direct marketing via email when you opt in for this purpose in the relevant contact form. You may opt out of receiving future marketing communications at any time.
· we may also store cookies as set out in more detail in our COOKIE POLICY
How we use your personal information
Your personal information will be collected and handled by us for the following purposes:
· to best tailor content and resources according to your preferences.
· to respond to your request or questions when you contact us.
· to send to you other information – such as TSI upcoming events or newsletters – that may be of interest to you.
· to help us create, publish and improve content most relevant to you.
· to ensure that the content provided through the Website is presented in the most effective manner for you and for your device.
· to allow you to participate in interactive features of our website, when you choose to do so.
· to further develop and improve the Website and systems to better serve you.
Our use of your information as described above is permitted by applicable data protection law because it is:
· necessary for our legitimate interests in pursuing the purposes set out above, and such interests in each case not being overridden by your privacy interests;
· in some cases, necessary to meet our legal or regulatory responsibilities, such as disclosures to authorities, regulators or government bodies; or
· in some cases, necessary for the performance of a task carried out in the public interest and, when we use special categories of personal information, necessary for establishing, exercising or defending legal claims or where the processing relates to personal information manifestly in the public domain;
· in limited circumstances, processed with your consent which we obtain from you from time to time, such as when you opt in to receive marketing communications and news via email.
We do not make any automated decisions solely on automatic processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
The retention periods of your personal information depend on the respective purpose for which the data is processed and the respective tool in which the personal information is processed in. It is not possible to outline the various retention periods in a reasonably intelligible format under this Policy. The criteria used to determine the applicable retention period are that we will retain the personal information set out in this policy for as long as (i) necessary for the respective purpose, (ii) necessary to carry out our business relationship with you, (iii) you have consented to, and/or (iv) required by applicable statutory retention laws.
Sharing with third parties
To facilitate our efficient use of your information, and to provide you with the content and/or resources, we disclose your information to third parties. However, this disclosure will only occur in the following circumstances:
To suppliers, contractors and agents: from time to time, we may engage or employ other companies and individuals to perform functions on our behalf. Examples include the hosting and/or maintaining of Website content, the provision of certain features contained on the Website, or the provision of marketing services. In some countries we engage third parties to operate on our behalf pursuant to a license agreement, and if your request for information applies to services or functions, they perform, we will provide such personal information as may be necessary for them to fulfill your request. All such recipients will only have access to your personal information as required by them to perform their functions and are not permitted to use such personal information for any other purposes. These recipients will be subject to contractual confidentiality obligations.
To government or law enforcement authorities if we determine in our sole discretion that we are under a legal obligation to do so.
IP addresses and cookies
We collect information about your computer, including (where available) your IP address, operating system, and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns and does not identify you or any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your device. Cookies help us to improve the Website and to deliver better and more personalized content. For more information about our use of cookies on the Website, please refer to our COOKIE POLICY.
If your computer is shared with other people, we advise that you do not select the ‘remember my details’ option when that option is offered by the Website.
Where your personal information is stored and processed
As explained in the “Sharing with third parties” paragraph above, we share your personal information with the following:
Third-party suppliers, contractors or agents: where we use a third-party supplier, contractor or agent, your personal information remains under our control and we have controls in place to ensure your personal information is adequately protected.
We endeavor to take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Policy.
Do we transfer your data outside the European Union?
Your personal information can be transferred and processed in one or more other countries, in or outside the European Union. We shall only transfer your data outside the EU to countries which the European Commission believes offer an adequate level of protection to you, or where we and our affiliated companies have put in place appropriate safeguards to seek to preserve the privacy of your information. Those countries include the United States.
E.U.-U.S. Privacy Shield
As stated above Transition Solutions Inc. 1 Batterymarch Park, Quincy, MA 02169 complies with the E.U.-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union to the United States.
TSI is responsible for the processing of personal information it receives under the Privacy Shield and subsequently transfers to any third party acting on its behalf. TSI complies with the Privacy Shield for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield, TSI is subject to U.S. Federal Trade Commission regulations and enforcement. In cases of onward transfer to third parties of personal information of E.U. individuals received pursuant to the Privacy Shield, we may remain liable for the acts of those third parties for their handling of personal information.
In compliance with the E.U.-U.S. Privacy Shield Principles, TSI commits to resolve complaints about your privacy and the collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact us at: privacy@transitionsolutions.com Please note that if your Privacy Shield complaint is not resolved through the above channels, a binding arbitration option may be available before a Privacy Shield Panel.
Data Security
Although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Website or any third party; for this reason, any transmission is at your own risk. We will use strict operational procedures and adequate, technical and organizational security measures to prevent any unauthorized access, change, deletion or transmission of this personal information.
Your rights. How you can access, correct and delete your personal information
Under applicable data protection laws, you have the following rights:
· Right to access and obtain a copy of your personal information: You are entitled to request confirmation whether we process any of your personal information. Where this is the case, you may have access to your personal information and to certain information about how it is processed. In some cases, you can ask us to provide you with an electronic copy of your information.
· Right to correct your personal information: If you can demonstrate that personal information, we hold about you is not correct, you can ask that this information is updated or otherwise corrected.
· Right to be forgotten/have data deleted: In certain circumstances you have the right to have your personal data deleted. You may make such a request at any time and TSI will evaluate whether your request should be granted. However, this right is subject to any legal rights or obligations we may have to retain data. For situations where, in accordance with the law, we determine that your request to have your personal information deleted must be granted, we will do so without undue delay.
If you want to exercise any of your rights send an email to privacy@transitionsolutions.com
To the extent our processing of your personal information is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of any processing based on your consent before the receipt of such withdrawal.
You can also lodge a complaint about our processing of your personal information with your local data protection authority.
California & Other U.S. State Privacy Rights
Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have rights to:
Access the categories and specific pieces of personal data TSI has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom TSI has shared personal data;
Delete personal data under certain circumstances;
Correct personal data under certain circumstances; and
Opt out of the “sale” of personal data or “sharing” of personal data for targeted advertising purposes.
We do not sell your personal data in the conventional sense. However, like many companies, we may use analytics services that are intended to analyze your interactions with our website, based on information obtained from cookies or other trackers, including for delivering interest-based content to you.
If, at any time after you have provided us with your Personal Information as described above, you decide that you want us to delete it from our records, please notify us by using either the following email or phone number: privacy@transitionsolutions.com or (888) 424-0003
We will respond to your request within 10 business days of receiving it, when we will ask you to verify your request, tell you how we will process it, and let you know when your Personal Information will be deleted.
Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or filling in the applicable form in the section “Getting in touch with us” below.
TSI will not discriminate against you for exercising any of these rights.
Sensitive Information. In limited instances, TSI receives information that may be considered sensitive under some laws.
Under CPRA “Sensitive personal Information” means any personal information that reveals:
· a consumer’s social security, driver’s license, state identification card, or passport number;
· a consumer’s account log-In, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
· a consumer’s precise geolocation;
· a consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
· the contents of a consumer’s mall, email and text messages, unless the business Is the intended recipient of the communication;
· a consumer’s genetic data; and
· the processing of biometric information for the purpose of uniquely identifying a consumer;
· personal information collected and analyzed concerning a consumer’s health; or
· personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.
Sensitive personal information that Is “publicly availale” is not be considered sensitive personal information or personal information.
TSI processes sensitive personal information to provide TSI products and services, for product research and development, for authentication, integrity, security, and safety reasons, to communicate with you, for legal reasons, and with your consent. TSI does not use or disclose sensitive personal information (as defined under CCPA) for purposes of inferring characteristics about a consumer, or in any way that would require TSI to provide a right to limit under the CCPA.
Profiling
Under certain laws, residents may also be permitted to opt out of certain profiling relating to automated processing analyzing certain categories of an individual’s information that would produce a legal or similarly significant effect. TSI does not engage in this type of profiling of individuals.
To exercise your rights, please notify us by using either the following email or phone number: privacy@transitionsolutions.com or (888) 424-0003.
To opt out of the use of cookies on our sites, follow the instructions above.
If you would like to submit an opt-out request for personal information that is not collected by cookies – such as your email address – please notify us by using either the following email or phone number: privacy@transitionsolutions.com or (888) 424-0003.
These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency. You may designate an authorized agent to submit your verified consumer request by providing written permission and verifying your identity, or through proof of power of attorney.
Disclosure of Privacy Rights Requests
The CCPA requires businesses to disclose the number of requests received, complied with in whole or in part, or denied.
Between January 1, 2021, and December 31, 2023, TSI received 0 privacy rights requests from USA data subjects which were fulfilled in whole or in part, and 0 privacy rights request which was denied. On average, all privacy rights requests were responded to within 10 days.
Examples of denied requests include requests that were not verifiable, requests that were not made by the consumer, and requests that were exempt from disclosure.
California’s Shine the Light Law
California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your Personal Information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for the third parties’ direct marketing purposes.
Marketing communications
We will only send marketing communications to you via email where you have consented that we may do so.
We will usually offer you a tick box on the forms we use to collect your personal information where, if you agree to receive marketing communications, you have to click the box. Where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the email. In addition, you can also exercise your opt-out right at any time by contacting us at marketing@transitionsolutions.com and providing the following information: your name, your email address, a contact telephone number, the marketing communications you would like to opt out of receiving.
Other TSI sites
We offer online tools and services through other websites which may be accessed through this Website and which have their own privacy policies that govern our handling of your personal information when you visit those websites.
Changes to this Policy
The terms of this Policy may change from time to time. We shall publish any material changes to this Policy through appropriate notices either on this website or contacting you using other communication channels.
Contact
Questions, comments and requests regarding this Policy are welcomed and should be addressed to us by mail at: Transition Solutions Inc. 1 Batterymarch Park, Quincy, MA 02169 ; or via email to privacy@transitionsolutions.com
You can request a copy of mechanisms relating to a specific transfer of your personal information by contacting privacy@transitionsolutions.com