PRIVACY POLICY

1.0 Overview

General Terms:
By accessing tcbmail.com (hereinafter “tcbmail”), you agree to be legally bound by the following terms. If you do not agree to be legally bound by all of the following terms then please do not access and/or use “tcbmail”. We may change these at any time and we’ll do our utmost in informing you, though it would be prudent to review this regularly yourself as your continued usage of “tcbmail” after changes mean you agree to be legally bound by these terms as they are updated and/or amended.

1.1 Purpose
tcbmail.com and its operating divisions, subsidiaries, affiliates and branches (collectively, “tcbmail,” the “Company,” “we” or “us”) are sensitive to privacy issues, and it is important to us to protect the information provided to us. Accordingly, tcbmail.com provides this privacy and information practices policy to inform you about our online information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information (“Privacy Policy”). By using the tcbmail.com Platform, you expressly consent to the information handling practices described in this notice.

1.2 Scope
This Privacy Policy applies to Personal Information that is Processed by tcbmail.com in the course of our business, including on Company websites (together with any and all future websites operated by or on behalf of tcbmail, the “Websites”). All individuals whose responsibilities include the Processing of Personal Information on behalf of tcbmail.com are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

This Privacy Notice is incorporated into and is subject to the tcbmail.com Platform Terms of Use. Your use of the tcbmail.com Platform and any personal information you provide through the tcbmail.com Platform are subject at all times to this Privacy Notice and the Terms of Use. Terms for “tcbmail” and the “tcbmail.com Platform” apply to any site or mobile application owned and operated by tcbmail.com and the tcbmail.com mobile application(s).

2.0 Transparency/Notice–What Personal Information We Collect and How We Use It
The types of Personal Information we may collect (directly from you or from Third Party-sources) and our privacy practices depend on the nature of the relationship you have with tcbmail.com and the requirements of applicable law. We endeavor to collect information only relevant for the purposes of Processing. Below are the legal bases and some of the ways we collect information and how we use it.

2.1 Individuals
tcbmail.com collects Personal Information regarding its current, prospective and former clients, customers, visitors and guests (collectively “Individuals”).

2.2 Information tcbmail.com Collects
The data we collect from or about current, prospective and former Employees, customers, visitors and guests (collectively “Individuals”) includes information that may be deemed Personal Information, such as title, name, address, phone number, email address, user name, and Internet Protocol address. We may also collect other information that is not Personal Information, such as demographic information you choose to provide (e.g., your business or company information, professional experiences, educational background, nationality, ethnic origin, gender, interests, preferences and favorites) and answers to a security question and password.

2.3 How tcbmail.com Collects Personal Information
Some of the ways that tcbmail.com may collect your Personal Information include:
tcbmail.com may collect Personal Information from you through various channels, including the Websites, in surveys, during business or marketing events, and when delivering programs and services to you.

When you use the Websites, tcbmail.com may provide you with opportunities to sign up to receive specific information or services and may ask for your contact information (e.g. name, e-mail address or personal email address), so that we can send you specific information about our products, services and specific health conditions, with your consent.

As you navigate the Websites, certain passive information may also be collected, including Internet Protocol addresses, cookies, navigational data, the name of the domain and host from which you access the Internet, the browser software you use and your operating system, the date and time you access our Websites, and the Internet address of the website from which you linked directly to our Websites. This type of information is used for the purposes of gathering data to provide improved administration of our Websites, and to improve the quality of your experience when interacting with our Websites.

2.4 Information from Third-Party Sources
We may collect information about you from third-party sources to supplement information provided by you. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you information about our business, products and services.

2.5 Research/Survey Solicitations
From time to time, tcbmail.com may perform research (online and offline) via surveys. We may engage Third Party-service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Websites, various types of communications, advertising campaigns and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes.

2.6 How tcbmail.com Uses Your Personal Information
Depending on how you interact with tcbmail, we and our Third Party-service providers may also use Personal Information in a variety of ways, including:

Providing Information and Services You Requested. tcbmail.com may use the Personal Information about you to provide you information that you may request, e.g. information about a product or program we are offering. tcbmail.com may also use your Personal Information to deliver a specific program or service to you, when you enrol to receive the program or service.

Such use may include: (a) generally managing your information and accounts; (b) responding to questions, comments and requests; (c) providing access to certain areas and features of the tcbmail.com Websites; and (d) permitting you to register for events or participate in webinars.
Administrative Purposes. tcbmail.com may use the Personal Information about you for its administrative purposes, including, without limitation, to: (a) measure interest in tcbmail’s Website, programs or services; (b) perform internal quality control; (c) verify identity; (d) send communications regarding the tcbmail.com Website, programs or services, your account, or any changes to any tcbmail.com policy or terms of service; (e) process payments; (f) prevent potentially prohibited or illegal activities; and (g) enforce our Terms of Use.

Marketing Products and Services. tcbmail.com may use the Personal Information about you to provide you with materials about offers, products and services offered by us, including new content or services on tcbmail.com Websites. tcbmail.com may provide you with these materials by phone, postal mail, facsimile or email, as permitted by applicable law. If you do not wish us to use your Personal Information for marketing purposes, you may contact us at any time to opt out of the use of your Personal Information for such purposes, as further described below.

Research and Development. tcbmail.com may use your Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products, processes and services.

Information Submitted Via Websites. You agree that tcbmail.com is free to use the content of any communications or other information submitted by you via the Websites, including any narratives, images, ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services.

However, tcbmail.com does not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a site will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Sharing Content with Friends or Colleagues. tcbmail’s Websites may offer various tools and functionality. For example, tcbmail.com may provide functionality on its Websites that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by tcbmail.com or any other Third Parties for any other purpose.

Pseudonymous Data. Including as discussed below in Section 2.12, tcbmail.com may use and share your anonymized or aggregated information within the tcbmail.com group of companies or with Third Parties for, research, analytics and any other legally permissible purposes.

Other Uses. tcbmail.com may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

2.7 Human Resources Data
N/A

2.8 Social Media
Generally, online social media resources are interactive tools that enable Data Subjects to collaborate and share information with others. Social media resources include, but are not limited to, social networks, discussion boards, bulletin boards, blogs, wikis, and referral functions to share web site content and tools with a friend or colleague.

tcbmail.com may collect Personal Information to enable Data Subjects to use online social media resources offered either by tcbmail.com or a Third Party. We may also enable you to use these social media resources to post or share Personal Information with others. When using social media resources, you should take into careful consideration what Personal Information you share with others.

If you use on online social media resource offered by a Third Party (“Third Party SMR”) through the tcbmail.com Website, you acknowledge that tcbmail.com may be able to access any information you make public through such Third Party SMR (such as your username, comments, posts and contacts) and other information your privacy settings on such Third Party SMR permit tcbmail.com to access. tcbmail.com will comply with the terms of this Privacy Policy and the privacy policies applicable to the social media resources it uses.

2.9 Direct Mail, Email and Outbound Telemarketing
Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings or phone calls from us with information on tcbmail.com or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions in Section 3 below.

2.10 Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.

2.10.1 Cookies
Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.

2.10.2 Pixel Tags/Web Beacons
A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

2.10.3 Social Media Widgets
Our Website includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

2.10.4 Analytics Information
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.

You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout

Our uses of such Technologies fall into the following general categories:

Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shopping-carts, saved search, or similar functions;

Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;

Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites

Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

2.11 Mobile Devices
tcbmail.com may provide websites and online resources that are specifically designed to be compatible and used on mobile devices. tcbmail.com will collect certain information that your mobile device sends when you use such websites or online resources, like a device identifier, user settings and the operating system of your device.

Mobile versions of tcbmail’s Websites may require that users log in with an account. In such cases, information about use of each mobile version of the website may be associated with user accounts. In addition, tcbmail.com may enable Individuals to download an application, widget or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to tcbmail.com to enable Data Subjects to access user accounts and to enable tcbmail.com to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. tcbmail.com may use personal or non-identifiable information transmitted to the Company to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices tcbmail.com provides.

2.12 Anonymous and Aggregated Information
tcbmail.com may use your Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the tcbmail.com Website or other online services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Websites. Anonymized or aggregated information is not Personal Information, and tcbmail.com may use such information in a number of ways, including research, internal analysis, analytics and any other legally permissible purposes. We may share this information within tcbmail.com and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

3.0 Choice/Modalities to Opt Out
You have the right to opt out of certain uses and disclosures of your Personal Information, as set out in this Privacy Policy.

3.1 General
Where you have consented to tcbmail’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by following the instructions in this Section 3. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out.

Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Data Subject, tcbmail.com will endeavor to obtain each Data Subject’s explicit consent (opt-in). Where consent of the Data Subject for the Processing of Personal Information is otherwise required by law or contract, tcbmail.com will comply with the law or contract.

3.2 Email and Telephone Communications
An “Unsubscribe” button will be provided at the top or bottom of each email communications sent by tcbmail.com so that you can opt-out. However, we may continue to send transaction-related emails regarding products or services you have requested in response to such request. We may need to send you certain communications regarding the tcbmail.com programs and services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Use or this Privacy Policy.

3.3 Human Resources Data
N/A

3.4 “Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. tcbmail.com does not recognize or respond to browser-initiated DNT signals. For information about “do-not-track”, visit http://www.allaboutdnt.org.

3.5 Advertising Choices
We may use certain tools offered by Third Parties that enable such Third Party to collect or receive information about actions users take on: (a) our Website and elsewhere on the internet through use of cookies, pixel tags and other storage technologies; or (b) a tcbmail.com mobile application and other mobile applications, in order to provide interest-based advertising.
Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you. Advertisements on Third-Party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

You can opt out of the collection and use of your information for interest-based advertising by going to http://optout.aboutads.info, http://www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ to limit collection through the Website or by configuring the settings on your mobile device to limit ad tracking through the mobile applications.
Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Websites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

4.0 Onward Transfer

4.1 Information We Share
tcbmail.com does not sell or otherwise disclose Personal Information about you, except as described in this Privacy Policy or as you explicitly consent. tcbmail.com endeavors to require third parties to which it discloses Personal Information to protect Personal Information using substantially similar standards to those required by tcbmail.com (and at least the same level of privacy protection as is required by the Privacy Shield Principles and this Privacy Policy), and to notify tcbmail.com if they make a determination they can no longer meet this obligation.

4.1.1 Service Providers
tcbmail.com may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders.

tcbmail.com has executed appropriate contracts with the service providers that prohibit them from using or sharing your personal information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

4.1.2 Business Partners
tcbmail.com may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested tcbmail.com may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with tcbmail’s. tcbmail.com requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which it was provided.

4.1.3 Information Disclosed for Our Protection and the Protection of Others
We may disclose information about you: (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce tcbmail.com policies or contracts; (v) to collect amounts owed to tcbmail; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Websites. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

4.1.4 Information Disclosed in Connection with Business Transactions
We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, any reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, tcbmail.com will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Privacy Policy.

4.2 Data Transfers
All Personal Information sent or collected via or by tcbmail.com may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, our servers, the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to tcbmail, you consent to the storage of your Personal Information in these locations.

5.0 Rights of Access, Rectification, Erasure and Restriction
You may seek confirmation regarding whether tcbmail.com is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may use any of the methods set out in this Privacy Policy to request access to, receive (port), restrict processing, seek rectification or request erasure of Personal Information held about you by tcbmail. Such requests will be processed in line with local laws. Although tcbmail.com makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which tcbmail.com is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, 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 it is commercially proprietary. If tcbmail.com determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, tcbmail.com will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

6.0 Retention
tcbmail.com retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Websites or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

7.0 Security
The security of all Personal Information provided to tcbmail.com is important to us, and tcbmail.com takes reasonable steps designed to protect your Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while tcbmail.com strives to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to tcbmail, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify us at legal@elvicities.com.

8.0 Redress/Compliance and Accountability
If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns, please contact us at legal@elvicities.com
tcbmail.com will address your concerns and attempt to resolve any privacy issues in a timely manner.

If you are an EU or Swiss citizen and feel that tcbmail.com is not abiding by the terms of this Privacy Policy, please contact tcbmail.com at the contact information provided above. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.

9.0 Other Rights and Important Information.

9.1 Information Regarding Children
Due to the nature of tcbmail’s business, services and benefits are not marketed to persons less than 13 years of age (and in certain jurisdictions under the age of 16 (collectively “minors”).
If you are under 13 years of age (and in certain jurisdictions under the age of 16), then please do not use or access the tcbmail.com platform at any time or in any manner.

Protecting the privacy of young children is especially important. For that reason, tcbmail.com does not knowingly collect or maintain personally identifiable information from minors. If tcbmail.com learns that personally-identifiable information of minors has been collected on or through the tcbmail.com platform, then tcbmail.com will take the appropriate steps to delete this information.

If you are the parent or legal guardian of a minor who has become tcbmail.com platform member, then please contact tcbmail.com at legal@elvicities.com to have that minors’s account terminated and information deleted.

The following are some resources that may help parents and legal guardians in monitoring and limiting your childrens’ access to certain types of material on the internet. While tcbmail.com does not endorse these products, we are providing information about them as a public service to our community.

“OnGuard Online,” maintained by the Federal Trade Commission.
WiredSafety
Netsmartz.org
The Child Safety Network
Control Kids
Cyber Sitter
Net Nanny

9.2 Links to Third-Party Websites
Please note that our Websites may contain links to other websites for your convenience and information. tcbmail.com does not control Third-Party websites or their privacy practices, which may differ from those set out in this Privacy Policy. tcbmail.com does not endorse or make any representations about Third-Party websites. Any Personal Information you choose to give to unrelated Third Parties is not covered by this Privacy Policy. tcbmail.com encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third Parties may choose to share their users’ Personal Information with tcbmail; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

9.3 Changes to the Privacy Policy
tcbmail.com may update this Privacy Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Privacy Policy, tcbmail.com will notify you by email or as otherwise required by applicable law. tcbmail.com encourages you to review this Privacy Policy periodically to be informed regarding how tcbmail.com is using and protecting your information and to be aware of any policy changes. Your continued relationship with tcbmail.com after the posting or notice of any amended Privacy Policy shall constitute your agreement to be bound by any such changes. Any changes to this Privacy Policy take effect immediately after being posted or otherwise provided by tcbmail.

9.4 Contact Information
Please contact tcbmail.com with any questions or comments about this privacy notice, your personal information, and our third-party disclosure practices or your consent choices by email: legal@elvicities.com. We will respond to your inquiry within 30 days of its receipt.
tcbmail.com Privacy Policy (Effective: May 25, 2018)