TLDR Global Privacy Policy

A. We care about your privacy

TLDR Global respects your privacy and is committed to protecting your personal data.

When you contact us through the website www.tldr.global, or when you engage our services, TLDR Global may obtain personal data about you. We will process such personal data in accordance with the applicable laws and regulations and with this Global Privacy Policy, as amended from time to time, and any applicable provision as may be individually agreed.

It is important that you read this Global Privacy Policy together with the Terms of Use of our website and the Cookie Policy, as well as any other privacy policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

TLDR Global is a brand that is meant to represent different legal entities. This privacy policy is issued on behalf of the TLDR Global Group so when we mention TLDR Global, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the TLDR Global Group responsible for processing your data. We will let you know which entity will be the controller for your data when you enter into an agreement with us. TLDR Universe Limited is the controller and responsible for this website.

In this policy you can find more about:

  • How do we collect your personal data;
  • What personal data do we collect;
  • Why do we need your personal data;
  • When do we share your personal data;
  • How do we protect your personal data; and
  • How can you exercise your data subjects rights.

1. How do we collect your personal data?

We use different methods to collect data from and about you including through:

1.1. Direct interactions. You may give us your data by filling in forms in our website or by corresponding with us by email. This includes personal data you provide when you:

  • enter into an agreement for, or hold formal or informal conversations with us in anticipation of, the provision of services;
  • subscribe to our newsletters, events or publications; or
  • give us feedback or contact us.

1.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data (defined below) about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

1.3. Indirectly. We may have access to your personal data because someone who has it engaged us to provide a service that requires us to access and use that data. In this case, we will be processing your personal data as data processors, on behalf of the data controller, who determines in exclusivity the types and purposes for which we will process your data and is solely liable to you for any data breaches not caused exclusively by us.

2. What personal data do we collect?

2.1. We collect and process, to the extent such data is adequate, relevant and necessary for the purposes outlined in (3) below:

  • Identity Data, which may include first name, maiden name, last name or similar identifier, and any other identity data required by applicable laws and regulations;
  • Contact Data, which may include electronic address and other contact details provided by you or required by applicable laws and regulations;
  • Professional Data, which may include the name of your company, your position and other professional details provided by you or required by applicable laws and regulations;
  • Technical Data, which may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
  • Usage Data, which may include information about how you use our website, products and services;
  • Marketing and Communications Data, which may include your preference in receiving marketing from us and our third parties and your communication and cookies preferences; and
  • Any other personal data provided by you in the course of your engagement with TLDR Global.

2.2. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Global Privacy Policy.

2.3. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

2.4. Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2.5. It is important that the personal data we hold about you is accurate, complete and up to date. Please keep us informed if your personal data changes during your relationship with us.

3. Why do we need your personal data?

3.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the agreement we are about to enter into or have entered into with you;
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  • Where we need to comply with a legal obligation.

3.2. Specifically, we may use your personal data for the following purposes:

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To provide the service, which may include sharing your data internally as well as disclosing it to third parties. (a) Identity data
(b) Contact data
(c) Professional data
Performance of a contract with you.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy;
(b) Asking you to provide feedback.
(a) Identity
(b) Contact
(c) Marketing and Communications
(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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). (a) Identity
(b) Contact
(c) Technical
(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 and understand the effectiveness of the advertising we serve to you. (a) Identity data
(b) Contact data
(c) Professional data
(d) Technical data
(e) Usage data
(f) Marketing and Communications Data
Necessary for our legitimate interests (to study how users use our services and website, 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 (a) Technical
(b) Usage
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 (a) Identity data
(b) Contact data
(c) Professional data
(d) Technical data
(e) Usage data
(f) Marketing and Communications Data
Necessary for our legitimate interests (to develop our products/services and grow our business)

3.3. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

3.4. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

3.5. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

4. When do we share your information?

4.1. Internally

In order to provide a reliable and consistent service, your personal data may need to be accessed by more than one of TLDR Global’s entities. This will involve transferring your data outside the European Economic Area (EEA). For example, one TLDR Global entity might share your information with another in order to facilitate the provision of different services as requested by you. When sharing your personal data, we adhere to applicable legal and industry standards regarding the protection of personal data.

4.2. To third parties

TLDR Global does not disclose your personal data to third parties, except as described in this policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services or somehow facilitate the provision of TLDR Global’s services, including those that provide professional, legal or accounting advice to TLDR Global. Non-affiliated companies that assist TLDR Global in providing services to you are subject to a confidentiality agreement and they receive and use your personal data only in the course of providing such services and only for the purposes established by TLDR Global.

We may also disclose your personal data under your instructions, to protect our rights and interests and those of our business partners or pursuant to your express consent. Finally, under limited circumstances, your personal data may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations; for instance, when responding to a subpoena or similar legal process, to protect against fraud and to otherwise cooperate with law enforcement or regulatory authorities or with organizations such as exchanges and clearinghouses.

TLDR Global will not sell your personal data. We may, however, transfer your data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

5. How do we protect your personal data?

We are committed to protecting the privacy and confidentiality of your personal data. Access to your data is limited only to authorized TLDR Global officers, employees, contractors or others who may require access to it in order to perform the services requested by you.

We hold both our team and our service providers to the highest standards of privacy. We maintain physical, electronic and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. More specifically, we have implemented the following security measures:

  • A team highly specialized in cyber and physical security, that designs, implements and provides oversight to our information security program;
  • The use of specialized technology such as host-based security tools, network defense monitors, and intrusion detection systems;
  • Testing of the security and operability of products and services before they are introduced to the Internet, as well as ongoing scanning for publicly known vulnerabilities in the technology;
  • Internal and external reviews of our Internet website and services;
  • Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
  • Implementing controls to identify, authenticate and authorize access to various systems or sites;
  • Protecting information during transmission through various means including, where appropriate, encryption; and
  • Providing TLDR Global personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

6. How can you exercise your data subject rights?

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us in writing to legal@tldr.global.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unreasonable, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

B. Miscellaneous

This policy provides the general framework for our approach to the processing of personal data. You may, however, in connection with specific products or services offered by TLDR Global, agree to different privacy provisions that supplement this policy.

Our website and services are not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the website without parental consent, unless such user is subject to a law where parental consent is not necessary. 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 on or through any of its features/register on the website, do not use any of the interactive or public comment 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, without parental consent. 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 legal@tldr.global.

If you wish to contact us for any matter related with the TLDR Global Privacy Policy or with how we process your personal data, please contact us at legal@tldr.global.