Privacy Policy

Personal Information We Collect

We collect personal information online, through our Website, and offline, pursuant to the services we provide to our clients and the information we collect directly from consumers (e.g. employment applications submitted by consumers). In particular, we have collected the following categories of personal information within the last twelve (12) months:

A. Identifiers, such as your IP address and name.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
C. Protected classification characteristics under California or federal law
D. Internet or other similar network activity
E. Geolocation data
F. Professional or employment-related information
G. Commercial information
H. Biometric information
I. Sensory data
J. Non-public education information
K. Inferences drawn from other personal information

These categories of personal information, listed above, are collected from the following categories of sources:

  • Directly from you. We collect information when you fill out a form on our website (e.g. when you request a consultation or choose to contact us), use the client login feature, subscribe to our blog, and submit to a pre-employment background check.
  • Indirectly from you. For example, from observing your actions on our Website, such as the date and time of your visit, the pages and content you view, and links you click on while navigating within our Site.
  • Directly or indirectly from our clients.
  • Open source intelligence, which is data collected from publicly available sources.
  • Our proprietary/subscription databases and investigative techniques.
  • Social media services, like Twitter, Facebook, or Instagram.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Use of Personal Information Collected

As defined by CCPA Section 1798.140, we may use, sell, or disclose the personal information we collect online for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information, such as conducting a background investigation as a part of pre-employment screening.
  • To provide support, personalize, and develop our Website and services.
  • To create, maintain, customize, and secure your account with us.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To respond to law enforcement requests at the direction of the client and their counsel and as required by applicable law, court order, or governmental regulations.
  • To send periodic emails, which may be regarding your project, offers for services you may be interested in, or other administrative notifications such as security or support and maintenance advisories.
  • To accomplish our business purposes, such as:
    • Providing security services, which include(s) executive protection, security consulting services, sport and entertainment security, sexual misconduct consulting, technical surveillance countermeasures, and our command center
    • providing cyber security services, which include(s) cyber incident response, information security, compliance technology consulting, and data forensics
    • providing intelligence services, which include(s) social media monitoring and threat analysis, global due diligence, destination intelligence briefings, and our command center.
    • providing investigative services, which include(s) financial investigation employment investigations, health care fraud and abuse, private investigations, and sexual misconduct investigations.
    • providing litigation support services, which include(s) deposition support, witness interviews, data analysis, legal strategy consulting, expert witness referrals, and global litigation support services.
  • For any other purposes disclosed to you in this Privacy Policy or at the time we collect your information or pursuant to your consent.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing and Selling Personal Information

We may disclose or sell your personal information to a third party for our aforementioned business purposes, subject to your right to opt-out of those sales.

We share and sell your personal information with the following categories of third parties:

  • Clients and their counsel who retain us for the aforementioned business purposes.
  • Law enforcement agencies at the direction of the client and their counsel and as required by applicable law, court order, or governmental regulations.

We have disclosed and sold the following personal information in the past 12 months:

A. Identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
C. Protected classification characteristics under California or federal law.
D. Internet or other similar network activity
E. Geolocation Data
F. Professional or employment-related information.
G. Commercial information
H. Biometric information
I. Sensory data
J. Non-public education information.

Do We Use Cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent or you can choose to turn off all cookies. You do this through your browser settings. Since every browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies. 

If you turn cookies off, some features will be disabled. Some of the features that make your site experience more efficient may not function properly.

California Residents

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Your Rights

1. Access to Specific Information Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories and specific pieces of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share(d) that personal information.
  • Two separate lists providing:
  • a list of the categories of personal information we have sold about you in the preceding 12 months by reference to enumerated category or categories that most closely describe the personal information sold, or if we have not sold your personal information in the preceding 12 months, we shall disclose that fact.
  • a list of the categories of personal information we have sold about you for a business purpose in the preceding 12 months by reference to enumerated category or categories that most closely describe the personal information disclosed, or if we have not disclosed your personal information for a business purpose in the preceding 12 months, the business shall disclose that fact.
2. Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request. we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

3. Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Exercising Your Rights

Access and Deletion Rights

To exercise the access and deletion rights described above in Parts 1 and 2 of this section (“Access to Specific Information Rights” and “Deletion Request Rights”), please submit a verifiable consumer request to us by either:

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to [45/90] days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Opt-Out Rights

To exercise your opt-out rights as described above in part 3 of this section (“Personal Information Sales Opt-Out and Opt-In Rights”), you (or your authorized representative) may submit a request to us by submitting a California Consumer Rights Request Form - Do Not Sell My Personal Information

You may change your mind and opt back in to personal information sales at any time by clicking here: Opt-In

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you services.
  • Charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of services.
  • Suggest that you may receive a different price or rate for services or a different level or quality of services.

Other California Privacy Rights

Shine the Light Law

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to DataPrivacy@tmprotection.com or write us at:

T&M Protection Resources, LLC
Attn: Privacy Request
230 Park Avenue, Suite 440
New York, NY 10169

California Online Privacy Protection Act

The California Online Privacy Protection Act (CalOPPA) requires operators of commercial websites and online services that collect California residents' personally identifiable information (PII) to conspicuously post a privacy policy.


Nevada Residents

The Nevada Revised Statutes Chapter 603A, also known as the Nevada Online Privacy Law (OPL), provides consumers (Nevada residents) with specific rights regarding their personal information. This section describes your OPL rights and explains how to exercise those rights.

Your Rights

Under Nevada law, a consumer may submit a verified request to prevent us from selling your covered information (“opt-out”) that is currently in our control or that will be collected in the future from our website.

However, opt-out requests will not be honored if the sale of covered information is for purposes consistent with the consumer’s reasonable expectations, when considering the submission’s circumstances.

Exercising Your Rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a Nevada Resident Opt-Out Form.

Response Timing and Format

We endeavor to respond to verified requests submitted by a consumer within 60 days of receiving this request. Depending on the request, we may extend the response period by 30 days if reasonably necessary; we will notify you if this occurs.

Federal Requirements

Children's Online Privacy Protection Act Compliance

Our Website is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, use any of the interactive features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at: (646) 445-7615

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see "Your California Privacy Rights" for more information.

CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries and/or other requests or questions
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CANSPAM, we agree to:

  • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at:

  • Follow the instructions at the bottom of each email and we will promptly remove you from our marketing, news, or ALL correspondence.

Changes to Our Privacy Notice

T&M Protection Resources, LLC reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information, your choices and rights regarding such use, or if you wish to exercise your rights under California or Nevada law, please do not hesitate to contact us at:

Phone: 212.422.0000
Website: www.tmprotection.com/privacy-policy
Email: DataPrivacy@tmprotection.com

Postal Address:
T&M Protection Resources, LLC
Attn: Privacy Request
230 Park Avenue, Suite 440
New York, NY 10169

 

EFFECTIVE DATE: JANUARY 1, 2020

LAST REVIEWED ON: DECEMBER 31, 2019