Toffler Associates, Inc. (“Toffler Associates,” “we” or “us”) recognizes the importance of protecting your Personal Information. This Privacy Statement (“Statement”) provides you with information about how Toffler Associates collects, uses, and discloses your Personal Information, and the rights you may have with respect to your Personal Information.
We commit to collecting and processing your Personal Information responsibly and in compliance with applicable data protection/privacy laws. This Statement generally applies to tofflerassociates.com and any Toffler Associates-owned websites or mobile applications that link to this Statement (collectively, “Toffler Associates Sites and Apps”).
Toffler Associates is a business-to-business and business-to government products and services provider. Accordingly, while we may collect and process customer data, which may include Personal Information (collectively, “Customer Data”), our normal business practice is to do so only at the request or direction of our customers and solely for the purpose(s) agreed to in the applicable customer contract. We collect and process such Customer Data responsibly and in compliance with applicable laws, regulations, and customer contract obligations.
Further, Toffler Associates policy requires limiting the collection and storage of personal information only to what is required for a legitimate business purpose.
How We Collect and Use Your Personal Information
“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity.
The categories of Personal Information we collect from you depend on your interactions with us. If you choose not to provide us with this Personal Information when prompted, we may be unable to provide you with the information or services you have requested. For example, we may collect:
- Identifiers and contact information, such as your name, email address, mailing address, phone numbers, social security numbers, government-issued IDs (such as driver’s licenses), IP addresses, and unique identifiers such as your usernames and passwords. We collect this information directly from you and from third-party sources for the purpose of communicating with you, verifying your identity, and providing our Services to you.
- Professional and employment-related information, such as your business name, your license number, calendar and scheduling information, and other information related to your business. We collect this information directly from you for the purpose of administering your Account and providing you our Services.
- Commercial information, such as products and services you have purchased from us. We collect this information to maintain registered member records, identify trends in our registered member relationships, and conduct business analytics.
- Profile information and inferences, such as information about your preferences and characteristics. We collect profile information by drawing inferences from the above categories of Personal Information in order to understand your preferences and tailor our services and communications to you.
In addition to the purposes for collection described above, we also collect your Personal Information for the following general purposes:
- Request a product demo, download or access information about our products, services or programs;
- Watch video content on our Sites and Apps;
- Submit a contact form to request customer or technical support;
- Apply for a job with Toffler Associates;
- Ask to have a Toffler Associates employee contact you;
- To respond to your requests and address your questions and concerns;
- To send you newsletters and marketing communications;
- To administer and improve our Services and marketing efforts, including measuring the effectiveness of the websites, diagnosing problems with our servers, and analyzing traffic;
- To detect security incidents, to protect against malicious, deceptive, fraudulent or illegal activity, and to comply with our policies and procedures;
- To comply with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims.
Use of Personal Information
We collect, use and share Personal Information when we have an appropriate legal basis to do this, such as:
- you have consented, for example, by signing up to receive communications or content from us or otherwise requesting access to information or materials that we make available via our Sites and Apps;
- our use of your Personal Information is necessary to meet our legitimate interests as a commercial organization (see Examples of Toffler Associates’ Legitimate Interests);
- our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, for example if you apply for a job with us or if you work for one of our service providers, customers, partners, prime contractors or subcontractors; and/or
- when necessary to comply with a relevant legal or regulatory obligation, for example, in response to an audit, subpoena or court order.
Examples of Toffler Associates’ Legitimate Interests:
- operating, maintaining, and improving Toffler Associates websites, products, services and programs;
- responding to comments and questions directed to us;
- providing customer service or technical support;
- sending information such as confirmations, invoices, technical notices, software updates, security alerts, and support and administrative messages;
- providing information requested by website visitors, current or potential customers, including but not limited to, educational content, fact sheets, webinars, white papers, upcoming events, and other news about products and services offered by us or our selected partners;
- protecting against, investigating, and deterring fraudulent, unauthorized, or illegal activity;
- process employment applications; and
- protecting Toffler Associates’ personnel or property.
We may also use what we know about you to highlight products and services that may be of interest to you, or we may combine your Personal Information and other information about you with information collected from offline sources or information we already have.
Sharing Personal Information
We process and share your Personal Information for the purposes set out in this Statement. When we disclose Personal Information to other entities or individuals to perform support services for us, we authorize such entities and individuals to use your Personal Information only for the limited purposes of performing those support services.
Please note that as a general rule, Toffler Associates cannot force third parties to abide by Toffler Associates’ policies. Nevertheless, we do contractually require third parties with whom we share employee data, Customer Data or other Personal Information to abide by appropriate and relevant contract obligations as well as applicable laws and regulations.
We may disclose Personal Information to:
- respond to questions about our product or services;
- send communications, including email newsletters, or other marketing materials;
- comply with applicable laws, obey judicial orders, respond to subpoenas; cooperate with law enforcement authorities, and respond to law enforcement requests;
- detect or prevent suspected or actual illegal activities or harm to our personnel or property;
- help us run our day-to-day businessoperations;
- protect the rights or property of others, including our customers; and
- respond to and/or assist our auditors and legal advisors.
We may also disclose Personal Information:
- when legally required (e.g., for government reports and investigations);
- with our affiliates;
- in connection with or in the performance of a sale, merger, acquisition, or other transfer of all or part of our business to another company, or as part of a bankruptcy proceeding or business reorganization or any due diligence relating to any such sale, merger, acquisition, or other transfer;
- for other legitimate business purposes, such as product or service development, marketing, sales and website administration; and
- as otherwise permitted or required by law.
We may share and disclose information that does not personally identify you when necessary for our business operations.
Authorized Service Providers. We sometimes hire or contract with other companies and individuals to perform certain functions and services on our behalf. This is a common industry practice. We may need to disclose Personal Information so that they can perform these functions and services, which may include, for example, call center/customer service support, sending or processing postal mail or email, and analyzing or hosting data on cloud-based servers.
Data Collected for Analytics, Marketing and Advertising Purposes
We market our business in a number of ways, primarily through digital advertising, social media platforms, email marketing and offline marketing, such as at trade shows and conferences.
Toffler Associates does not use this information to identify you. Network or device identifiers – such as computer or device IP addresses and serial numbers – do not themselves identify individuals who use such computers or devices. However, some jurisdictions’ laws may define these network or device identifiers as Personal Information.
We, and our service providers, use several industry standard analytics and tracking tools to collect Analytics Data, such as browser cookies, flash cookies, web beacons and other, similar technologies.
We use Analytics Data to:
- identify new visits to Toffler Associates websites;
- recognize returning visits;
- analyze the effectiveness of our website content and marketing or advertising-related activities;
- better understand Toffler Associates’ current and potential customers, website visitors and mobile app users;
- determine whether Toffler Associates’ current and potential customers, website visitors, and mobile app users might be interested in additional content, new products or services; and
- tailor our marketing and business development campaigns to individuals who we think may be interested in learning more about our products and services.
You can also set your preferences for Toffler Associates websites by reviewing the Cookie Settings. This feature allows you to set your cookie preferences when you visit Toffler Associates domains. Note that limiting the placement of cookies may result in certain features of our Sites and Apps not functioning as intended.
Please also note that we may use Google Analytics to measure and understand how visitors use our Sites and Apps. You can learn more about how Google uses the information it collects by visiting its website at www.google.com/policies/privacy/partners. You can opt out of Google’s collection of this information by downloading the Google Analytics Opt-Out Browser Add-On at https://tools.google.com/dlpage/gaoptout?hl=en.
You have certain choices with respect to the information we collect for advertising and marketing purposes. This section provides you with information about the choices you may have to control the information we collect about you for these purposes and how we use it.
Direct Marketing Communications. You can opt out of receiving direct marketing from us or change your marketing preferences by contacting us here.
You can opt out of receiving email marketing communications at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we may continue to send you service-related communications even after you opt out of receiving marketing communications.
You may also be able to opt out of receiving push notifications from mobile apps and text messages if you decide that you no longer wish to receive such communications. You may be able to use your device or app settings to manage your push notification preferences with respect to any of our Sites and Apps. If you previously agreed to receive text messages from us, but you no longer want to receive such messages, you can follow the instructions provided to you, which may include replying “STOP” to any such messages.
You can learn more about interest-based advertising by visiting the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) websites. You can also learn how to opt out from the collection of your information for interest-based advertising purposes by third parties that participate in these self-regulatory programs by visiting the NAI and DAA opt- out pages.
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Minors and Children under 16
Toffler Associates websites are not directed to nor intended for use by minors. We do not knowingly collect any Personal Information or knowingly track the use of Toffler Associates Sites or Apps by children under the age of 16.
Safeguarding Your Information
The integrity, availability and confidentiality of your Personal Information matters to us. That is why we use industry-standard technical, administrative and physical controls to protect Personal Information from unauthorized access, use and disclosure. We also review and evaluate our security procedures and controls on an ongoing basis to consider appropriate new technology and updated methods to help minimize risks from new security threats as they become known.
We will retain your Personal Information for as long as required for the purposes for which it was collected. How long we retain it depends on a number of factors, including the purpose for which it was obtained and/or our legal or regulatory obligations. For example, we may store your Personal Information for longer periods of time where we are required to do so to meet legal, regulatory, tax, or accounting requirements. We may also store it for longer periods of time to have an accurate record of your interactions with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation.
Additionally, Toffler Associates has a Records Retention Policy and schedules that address data retention and destruction for specific type(s) of records. This policy specifies how records maintained by Toffler Associates are to be retained and deleted, in compliance with applicable laws and best practices for the retention of records.
You should be aware that hyperlinks on this site may direct you to other websites that we do not control. These websites may be subject to a different privacy statement. Toffler Associates is not responsible for the privacy practices or the content of websites to which we link, list, rank or identify by means of a search. Toffler Associates takes no responsibility for the products, services, policies or actions of third parties or the content of third-party websites. We encourage you to be aware when you are leaving our site and to read the privacy policies of each website you visit.
International Data Transfer
If you use a Toffler Associates Site or App, your Personal Information may be transferred to or accessible by individuals working in the United States or other countries.
By continuing to use Toffler Associates Sites, you authorize Toffler Associates and its service providers to transfer your Personal Information to – or make it available in – destinations outside your home country and to process it according to this Statement. You may contact us at privacy@Toffler Associates.com for more information about the safeguards used to protect your privacy if we transfer your Personal Information outside of your country of residence.
Questions and Complaints
If you have any questions, complaints, or wish to send us comments about this Statement, please send an e-mail to privacy@Toffler Associates.com. We will investigate your complaint, and respond as soon as possible.
If you submit a complaint that relates to processing of Customer Data, Toffler Associates will communicate your complaint to the relevant customer for a response (unless it has been agreed otherwise with such customer). As stated above, Toffler Associates will adhere to customer contract obligations regarding Customer Data.
Changes to this Privacy Statement
We may update this Statement periodically. We will notify you of any changes by posting the new Statement at Toffler Associates.com/privacy, and we will change the “Last Updated” date above. You should consult this page regularly for any changes.