Table of Contents
Personal data, or personal information, means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include data where the identity has been removed (anonymous, deidentified or aggregate data). It also does not include publicly available information.
For the purpose of carrying on our business and providing our products and services, including registration and administration of our website and related products and services (including relevant online services), we may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:
We use different methods to collect data from and about you including through:
TCHI may use the personally identifiable information you choose to submit through the Site to communicate with you about our products and services. When we collect this information, we may store it in our computer systems. Do not submit any information via this Site that you do not want us to store or use. If you do not want to submit information through this Site, contact us instead.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer/user
Performance of a contract with you.
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communication
(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communication
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy.)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business).
We may use your personal information to form a view on what we think you may want or need, or what may be of interest to you.
You may receive marketing communications from us where you have utilized services from us as an individual customer or if you have requested information from us and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by contacting us and requesting that you be removed from emails related to a specific marketing campaign.
We will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
We may share your personal data with the parties set out below to enable us to carry out the activities specified in the table above:
We require all third parties to safeguard your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to TCHI employees, agents, contractors and other third parties working with or on behalf of TCHI who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
TCHI does not target, market to, or offer its products or services to children under the age 13 who are living anywhere in the world. TCHI does not target, market to, or offer its products or services to anyone living outside the United States, which includes children under age 16. If TCHI learns a child under age 13 living in the United States or a child under age 16 living outside the United States submitted through the Site the child’s personally identifiable information without parental consent or TCHI learns it collected information about the child through the Site, TCHI will take reasonable and appropriate steps to delete it.
If TCHI sells its assets to or is acquired by another company, or if TCHI merges with another company, you, by using this Site, authorize TCHI to assign the personally identifiable information you provided to TCHI or that TCHI collected while you used this Site.
If you submit your personally identifiable information through this Site, TCHI may send you emails. If you receive an email from TCHI that you did not want to receive or if you want TCHI to stop sending you emails after you receive one from TCHI, notify the email’s sender or follow the unsubscribe instructions in the email. TCHI will use reasonable and appropriate measures to honor your request.
TCHI uses reasonable and appropriate measures to safeguard the information you submitted to us through the Site or that TCHI received about you through the Site. You agree by using this Site that you understand that no transmission of information over the Internet can be guaranteed to be totally secure. If you do not want to transmit information to TCHI because TCHI cannot and does not guarantee it will be 100% secure during its transmission, do not submit personally identifiable information through the Site, contact us instead.
Utilizing the Site is voluntary. You may view most of the Site without registering or submitting your personally identifiable information through the Site. Some portions of the Site may only be available to users who have registered. If you want to stop receiving the information you requested when you registered, to update the registration information you submitted, or to correct any personally identifiable information in or remove any personally identifiable information from TCHI’s computer systems, send an email to email@example.com indicating your request. TCHI will use reasonable and appropriate measures to honor your request.
This Policy was written in English. To the extent a translated version conflicts with this Policy, the English version will take priority.
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