What personal information might TUSA collect from you?
Personal information is any information that personally identifies you or from which you could be identified. This may include your name, address, telephone number, email address and profession or occupation.
You may choose to give us personal information directly in a variety of situations. For example, when you:
• place product or services orders with us;
• create a user profile to access one of our online platforms or support portals;
• make information requests or complaints;
• sign up for or respond to marketing communications, surveys, newsletters or support communications;
• submit credit applications, job applications and event registrations; or
• visit or browse TUSA websites.
We may receive and process personal information on behalf of business customers. In such cases, TUSA will use such data only pursuant to our business customers’ instructions and only for purposes consistent with providing them with the contracted services.
The types of personal information TUSA may collect include personal and business contact information, such as name, address, telephone number, email address and any other data you actively choose to provide. In some cases, your business contact data may be provided to TUSA by a designated entity within your business or enterprise (such as a member of your IT or procurement department). You may also provide financial information, such as your credit/debit card number or other billing information. Other unique information such as user IDs and passwords, product and service preferences, historical information on product and services purchases, contact preferences, educational and employment background, and job interest data may be provided to us as well. Certain of our products and services enable the automatic collection of unique identifiers and geo-location data such as your mobile device identifier, IP address, web logs, or physical location when you request location based services.
TUSA may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous or aggregated information about how users use our websites, products or services to identify trends and better understand users’ behavior.
What about Cookies?
We may partner with a third party to either display advertising on TUSA Sites or Services. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by following the links provided within the applicable TUSA Sites or Services. Please note this would not opt you out of being served ads. You would continue to receive generic ads.
How might we use information collected from you?
We want to give you and all of our users the best possible services and a positive user experience. We may use the information we collect from you in the following ways:
• To provide, maintain, tailor and improve the TUSA Sites or Services;
• To provide you with customer support and troubleshoot problems;
• To inform you about service updates and faults;
• To request feedback or participation in on-line surveys;
• To resolve disputes;
• To verify your identity;
• To customize, measure, and improve the TUSA Sites or Services;
• To organize and carry out TUSA’s marketing or promotional activities. If you do not wish to receive these offers, please send us an email to unsubscribe or follow the unsubscribe link included in these emails;
• To protect TUSA, you and others that use TUSA’s Sites or Services.
Where necessary, TUSA may also use information provided by you or your employer, together with information from publicly available and other online and offline sources, to conduct due diligence checks on business contacts as part of TUSA’s anti-corruption and export compliance practices.
Will TUSA share any of the information it receives?
We neither rent nor sell your information to anyone. We don’t share your information with other organizations or individuals outside of TUSA, except as described below.
• When we have a good-faith belief that it is reasonably necessary to protect the rights or property of TUSA, our business partners, suppliers, clients, or others when we have reasonable grounds to believe that such rights or property have been or could be affected. In addition, we reserve the right to disclose your personal information as required by law and when we believe that disclosure is necessary to protect our rights, or the rights of others, or to comply with a judicial proceeding, court order, or legal process.
• With your permission.
We may share anonymous or aggregate data publicly and with our partners. For example, we may share information publicly to show trends about the general use of TUSA Sites or Services. Your information may be stored and processed in the United States or any other country in which TUSA, its affiliates, subsidiaries, or service providers maintain servers. As such, TUSA reserves the right to transfer your information outside of the country in which you live. By using our Web Site or our services you consent to any such transfer.
For strategic or other business reasons, TUSA may become involved in a sale, purchase, merger, or other reorganization of the business in whole or in part. Such a transaction may require disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is TUSA’s practice to seek appropriate protection for information in these types of transactions.
Information Security and Accuracy
TUSA intends to protect your personal information and to maintain its accuracy. TUSA implements reasonable physical, administrative and technical safeguards to help us protect your personal information from unauthorized access, use and disclosure. We also require that our suppliers protect such information from unauthorized access, use and disclosure.
What other choices do I have?
As stated previously, you can always opt not to disclose information, even though it may be needed to take advantage of certain TUSA Sites or Services.
We will retain your information for as long as your account is active or as needed to provide you services and comply with our corporate policies and practices. If you wish to request that we no longer use your registration information to provide you services, contact us at the addresses listed below. Please note that some information may remain in our records after deletion of your account. We will retain and use your registration information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
EU-U.S. Privacy Shield Framework
On July 16, 2020, the Court of Justice of the European Union (EU) issued a judgment declaring as “invalid” the adequacy of the protections provided by the EU-U.S. Privacy Shield Framework for personal data received from persons in EU member countries. This has not affected how TUSA manages the protection of your personal data. TUSA continues to maintain compliance with the Principles of the Framework while the decision of the Court of Justice of the EU is appealed and is committed to subjecting all personal data received from EU member countries to strict privacy measures as it has done in the past.
It is important to clarify that it is not necessary for TUSA to access, manage, process, sub-process, or otherwise access customer’s data to perform its services, and neither does TUSA actively monitor the processing of customer’s personal data. Nonetheless, TUSA is committed to ensuring protection of all personal information that we may hold. To that end, TUSA has secured the following certifications, all of which validate the appropriate and efficient physical and logical controls in place in our systems, services and infrastructure, designed to safeguard your personal data:
• SOC 1, Type II – ISAE 3402 (SSAE-18)
• SOC 2, Type II – ISAE 3402 (SSAE-18) – Security & Availability
• ISO 27001:2013
• PCI-DSS v3.2 – Medios de Pago (VSF)
• Compliance with the General Data Protection Regulation (GDPR)
Should you have any detailed questions regarding TUSA’s forthgoing posture vis-à-vis the EU-U.S. Privacy Shield Framework, you may direct them to the address included below.
Questions or Concerns
In certain cases, you may have the ability to view or edit your personal information online. In the event your information is not accessible online, and you wish to obtain a copy of particular information you provided to TUSA, or if you become aware the information is incorrect and you would like us to correct it, please contact us.
Before TUSA is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. We will contact you within 30 days of your request.
If you have any questions or concerns regarding privacy at TUSA, please send us a detailed message at:
Attention: Legal Director
Telefonica USA, Inc.
800 Waterford Way
Miami, Florida 33126
Email address: firstname.lastname@example.org
We will make every effort to resolve your concerns.
Effective Date: 09/17/2020