Privacy Policy under GDPR regulation - TBA Mobile App

This privacy policy describes how our company collects, uses and discloses your personal information and data when you use our services through our websites and/or application.

What kind of data is collected?

Our company collects the following set of data and information:

Personal identification information (name, physical address, email address, phone number…)
Images, videos

How is the data collected?

You provide our company with most of the data we collect, we collect data and process personal data and information when:

You register online
Use our website or application when cookies are set on your device

Our company might also receive data and information indirectly from the following sources:

TBA website (https://www.tba.com)
Vive (https://www.vive.com)
Facebook (https://www.facebook.com)
Twitter (https://www.twitter.com)
LinkedIn (https://www.LinkedIn.com)

How will we use your data?

Our company collects your data so that we can:

Process your business, manage your account
Send you email with sales ideas and updates on your business

If you agree our company will share your data with partner companies so that they may offer you their products and services:

Hubspot
Life Insurance Carriers

How is the data stored?

Our company securely stores your data in France (Europe).

Our company will keep your Device model, OS version, Device language, Country, City & golocalisation for the time period you have the app. Once this time period has expired, we will delete your data by destroying all records of it from our system.

Device model (anonymous)
OS version (anonymous)
Device’s language (anonymous)
Geolocalisation if provided
Country (deducted from geolocalisation)
City (deducted from geolocalisation)

Marketing

Our company would like to send you information about products and services of ours that we think you might like as well as those of our partner companies:

Vive
SalesLink
Life Insurance Carriers

If you have agreed to receive marketing emails or communication you may always opt out at a later date.

You have the right at any time to stop our company from contacting you for marketing purposes or giving data to other partners working with our company.

If you no longer want to be contacted for marketing purposes you can contact us at: mmynatt@tba.com.

Data protection rights

Our company would like to make sure you are fully aware of all your data protection rights. Every user has, if applicable, the right to:

The right to access: you have the right to request our company for copies of your personal data.
The right to rectification: you have the right to request that our company corrects any information you believe is inaccurate or mistaken. You also have the right to request our company to complete information you believe is incomplete.
The right to erasure: you have the right to request that our company erase your personal data under certain conditions.
The right to restrict processing: you have the right to request that our company restricts the processing of your personal data under certain conditions.
The right to object to processing: you have the right to object to our company’s processing of personal data under certain conditions.
The right to data portability: you have the right to request that our company transfers the data we have collected to another organization or directly to you under certain conditions.

If you have any request regarding this matter we have a month to answer you. If you want to exercise any of these rights please contact us by using the following contact detail:

Send us an email at: info@tba.com or mmynatt@tba.com

Privacy policies of other websites or third-party

Our company’s website might contain links to other websites, our privacy policy applies only to our website and/or application and services so if you click on another website you must read their privacy policy.

Changes to our privacy policy

Our company keeps its privacy policy under regular review and places any updates on this web page, this privacy policy was last updated on 07/20/2023.

Contacting us

If you have any questions or demand about our privacy policy, the data we hold on you, or you would like to exercice one of your data protection rights, please contact us at:

Send us an email at: info@tba.com or mmynatt@tba.com

Contacting the appropriate authority

If you have any complaint or concern regarding how your data is managed you can contact the appropriate authority at:

CFPB at https://www.consumerfinance.gov/data-research/consumer-complaints/

PRIVACY POLICY under other regulations than GDPR

Our company is committed to protecting individual privacy and securing the personal information made available to us when you visit. This privacy policy describes what information is made available to our company and how that information is used and retained and provides information on:

Information we receive (when you provide it, visit our website, receive email…)
How this information is used
Sharing of this information
Data retention
Third-party tools and sites
Children and privacy security

If you have any question or suggestion for its improvement, please let us know at (INSERT RELEVANT EMAIL ADDRESS)

Information you give us

You do not have to provide our company with any personal information or create a user account to access information on our website and/or application. However for some services we may need personal information from you such as: (CHECK AND MODIFY IN ACCORDANCE WITH THE TYPE OF DATA COLLECTED)

Personal identification information (name, physical address, email address, phone number…)
(ADD ANY OTHER PERSONAL DATA THAT IS COLLECTED BY YOUR COMPANY)

Also when you visit our website the following information is automatically received and stored by servers:

IP address
(INSERT DATA AND INFORMATION COLLECTED)

Third-party websites

Our company’s website and/or application might contain links to other websites, our privacy policy applies only to our website so if you click on another website you must read their privacy policy.

How information is used

If you choose to provide us with information we may use that information to contact you, respond to your message or provide information or services you requested.

We use data you provide and automatically generated data for statistical analysis to assess what information is of interest to users and system performance. This allows us to make general improvements to our site. We may also use your information in order to detect, prevent and respond to security issues and harmful activities on our website and/or application.

Sharing of this information

Information you choose to share with our company may be treated as public information.

Our company uses a third-party analytics provider (such as Google Analytics) to analyze data from cookies. The third-party analytics provider does not receive personally identifiable information through these cookies. We have also limited the provider’s ability to see your full IP address.

Within our company we restrict access to personally identifiable information to employees, contractors and vendors subject to non-disclosure requirements who require access to this information in order to perform their official duties and exercise controls to limit what data they can view based on the specific needs of their position.

We do not use or share your information for commercial purposes and except as described above, we do not exchange or otherwise disclose this information.

Link to external websites and third-party

Our website may link to other websites created and maintained by other private and/or public organizations and individuals. When you follow a link to an external site you are leaving our website and are subject to external site’s privacy and security policies. Our company does not control or guarantee the accuracy, relevance, timeliness or completeness of information contained on an external site.

Security

Our company takes reasonable precautions to protect our site and information. For example we restrict access to personally identifiable information to employees, contractors and vendors subject to non-disclosure requirements.

Our company also uses commonly used practices and technical controls to protect the information in our possession or control. These practices and controls include, but are not limited to, encrypting the transfer of personal information over the internet, using firewalls and intrusion detection systems and maintaining strict technical controls and procédures to ensure data integrity.

We periodically review our processes and systems to verify compliance with industry best practices and to ensure the highest level of security for our website.

Updates do this privacy policy

Our company will revise or update this policy from time to time, if we make significant changes to how we handle personal information we will post changes to the policy on our site and change the date at the end.

Updated on: 07/20/2023

Cookie Policy and other similar tracking technologies (GDPR and non GDPR)

When you visit TBA Mobile we may send cookies or other similar tracking technologies to your computer or to any other device you use. We use cookies and similar tracking technologies to track user’s preferences and to know how he uses our services.

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

For further information visit allaboutcookies.org

Cookies are used for user identification and proper assignment of historical user data collected during previous visits.

Both temporary cookie files (session cookies) and persistent cookies are used. Users may delete or remove cookies for the browser at any time or block cookies from being installed on its device. However this may affect the operation of our services or even result in its blocking.

As described above, we use your personal information and data to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For example (CHECK THE COOKIES YOU ARE ACTUALLY USING):

(INSERT IF APPLICABLE) We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

(INSERT IF APPLICABLE) We use a Facebook pixel on our website. Using the pixel, Facebook collects information about the users and use of our website. The information is used to personalize Facebook advertisements and to analyze the use of our website. To find out more about the Facebook pixel and about Facebook's use of personal data generally, see the Facebook cookie policy at https://www.facebook.com/policies/cookies/ and the Facebook privacy policy at https://www.facebook.com/about/privacy. The Facebook cookie policy includes information about controlling Facebook's use of cookies to show you advertisements. If you are a registered Facebook user, you can adjust how advertisements are targeted by following the instructions at https://www.facebook.com/help/568137493302217.

(INSERT IF APPLICABLE) We publish Google AdSense advertisements on our website, together with advertisements from the following advertisers and advertising networks that are distributed by Google: (identify and provide links to advertisers and networks). The advertisements may be personalized to reflect your interests. To help determine your interests Google and its partners use cookies. The relevant cookies served from our website are (MAKE A LIST OF COOKIES USED). The cookies are used to track your previous visits to our website and your visits to other websites. You can opt out of Google's personalized advertising by visiting https://www.google.com/settings/ads and you can opt out of third party cookies used for personalized advertising by visiting http://www.aboutads.info. You can review Google's privacy policy at https://policies.google.com/privacy.

(INSERT IF YOU USE A THIRD PARTY MARKETING APP THAT COLLECTS INFORMATION ABOUT BUYER ACTIVITY ON YOUR SITE OR APPLICATION) We share information about your use of the Site, your purchases, and your interaction with our ads on other websites with our advertising partners. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other similar technologies (which you may consent to, depending on your location).

(INSERT OTHER ADVERTISING SERVICES USED)

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at https://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:

(ADD OPT-OUT LINKS FROM WHICHEVER SERVICES BEING USED)

FACEBOOK - https://www.facebook.com/settings/?tab=ads
GOOGLE - https://adssettings.google.com/authenticated

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: https://optout.aboutads.info/.

We can use different type of cookie or tracking technologies while you are visiting our website and/or application:

Strictly necessary cookies: These types of cookies enable you to access and browse websites and use their features. Without these cookies, services like billing or shopping baskets cannot work properly.
Performance cookies: these cookies collect information and data about how you use our websites and/or application. The data collected can be used to optimize our websites and/or applications. These cookies are used to know where our visitors and users are coming from. These cookies do not collect information that identifies you personally.
Functionality cookies: these cookies allow our website or application to remember your choices. They can be used to memorize your localisation, or your preferences such as language settings or font size.

How to manage cookies?

You can set your browser not to accept cookies and the above website and/or application tells you how to remove cookies from your browser. However some of our websites and/or applications might not work properly without the use of cookies.

Here are some of the main explanation on how to delete cookies on your browser: https://support.google.com/chrome/answer/95647 (Chrome); https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox); https://help.opera.com/en/latest/security-and-privacy/ (Opera); https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer); https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac (Safari); and https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

For mobile devices, if you don’t want to receive targeted advertising based on your center of interest coming from a mobile application, please check the parameters of the operating system of your mobile device and follow these instructions: 1) iOS Users: to enable “Limited Ad Tracking” follow the instructions given by Apple. 2) Android Users: to enable the option “deactivate ad personalisation”, follow the instructions given by Google on Google Play. 3) You might want to download the DAA mobile AppChoices application to control behavioral advertising online.

Cheryl Coggins

Case Manager (I-Z)