Privacy and Data Protection Policy
Last updated May 2023
Collection and Use of Personal Data
Personal Data includes means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
What Personal Data do we collect?
The following information reflects Personal Data that we may collect or may have already collected about you over the past 12 months.
Personal Data voluntarily provided by you:
When you access, use and/or interact with our Websites, we may directly collect information you voluntarily provide us, such as when you download content or contact us, which includes:
- •If you express an interest in obtaining additional information about our services, use our “Contact Us” or similar features, request a demo, or download certain content, we may require that you provide to us your contact information such as your name, job title, company name, phone number, or email address.
- •When you register or request further information or services from us or participate in interactive features of our Websites.
- •When you report a problem with our Websites.
Personal Data collected from third parties:
In relation to utilizing our Websites, we may acquire, and use data obtained from external sources. As an example, to evaluate the efficacy of our Websites and advertising efforts, Tompkins could make use of a third-party entity for reporting and analysis, in addition to recognizing areas that need improvement.
We may also obtain business information and your Personal Data such as your name, title, company name and email from third party sources, as permitted by applicable law, from various third parties such as the following:
- •lead generation services, opt-in lists, data aggregators, and professional event organizers.
- •business partners of Tompkins as part of their referral activities.
- •public databases and any data that you may have made publicly available, such as social media posts on professional networks and social media platforms.
- •information shared with us by a third party who recommended you.
Collection and Use of Personal Data
While browsing our Websites, we may record certain details about your visits such as your IP address, web habits, web traffic, and location data. We may also keep track of other data, like your computer or mobile and internet connection specs, including OS, device type, and browser type.
How Do We Use the Personal Data Collected?
We may use Personal Data that we collect about Website visitors for the following purposes:
- •To protect the security of our Websites.
- •Enable the sharing of content across various social networks.
- •Enhance the function, performance, and services on the Websites.
- •To track your browsing behavior on the Websites, such as the pages you visited over time.
- •To present our Websites and their contents in a suitable and effective manner for you and for your computer.
- •To diagnose and resolve technical problems with our Websites.
- •To improve our Websites.
- •To provide you with information, products or services that you request from us.
- •To notify you about changes to our Websites or to obtain any required consent.
- •To allow you to participate in interactive features of our Websites, when you choose to do so.
- •For industry analysis, benchmarking, analytics, marketing, and other business purposes.
In the case where you wish to be informed about our Services, we may use (or permit select third parties to use) your Personal Data for this purpose. However, you may opt-out of this consent anytime by selecting the “unsubscribe” or “Update Subscription Preferences” links located in emails sent by Tompkins.
How Do We Share the Personal Data Collected?
Subject to any applicable data privacy law, or regulation, we may share, disclose, or transfer Personal Data that you provide to us to the following third parties:
To a buyer, investor, new affiliate, or other successor in the event Tompkins, or any affiliate, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of any assets of Tompkins or any affiliates or during steps in contemplation of such activities (e.g., negotiations and due diligence).
We may also disclose your Personal Data to third parties to:
- •Comply with any court order or other legal obligation.
- •Protect the rights, property, or safety of Tompkins or others.
We do not sell, rent or trade information collected through the Websites or the Services to third parties.
How long do we keep a visitor’s Personal Data?
In line with our record retention policies and to ensure the security of your Personal Data, we, in our sole discretion, will determine the amount of time that we store such data for in accordance with the initial purpose for which it was collected. This period of retention will take into consideration the nature and sensitivity of the data, the risk of harm it may pose if not protected, and whether we are able to fulfil our purpose for collecting the data by other means. At the end of the pre-determined retention period, all data will be fully removed from our systems and measures put in place to guarantee that it is not accessible in any way.
Your personal data may be transmitted and handled by us, our associates and other entities located in a country that is different from your home country or country of residence. Such different country may not have the same level of security as the rest of the world when it comes to data protection and privacy regulations. By giving us your details and accepting our conditions, you consent to this transfer and processing.
At Tompkins, we are cognizant of the need to safeguard the privacy and safety of minors. The services we provide are not tailored for anyone aged thirteen and below. We do not acquire any Personal Data from individuals at or below this age without obtaining permission from their parent or guardian. We ask that anyone aged thirteen and below refrains from using our services. If it is determined that any Personal Data from children under thirteen has been acquired without a guardian’s approval, it will be immediately deleted. If you believe we might have information related to a minor under the age of thirteen, please do not hesitate to reach out to us.
Class Action Waiver
YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR OUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.
6435 Hazeltine National Dr., Suite 105
Orlando, FL, 32822
Attn: Data Privacy