PRIVACY POLICY

Privacy Policy

This privacy policy (“Policy”) sets out how The Garage Group, Inc. (“TGG”) uses and protects the personal information you provide to TGG or on or through the TGG website, www.thegaragegroup.com (hereinafter, the “Site”).

TGG is committed to protecting your privacy.  Accordingly, any personal information you provide to us when you use this Site shall be used in accordance with the conditions outlined in this Policy. However, this Policy applies only to information collected directly by TGG or by the TGG Site.  This Policy imposes no duties on TGG not imposed by state, federal, or other applicable law.

TGG may change this Policy periodically by updating this Site. You should check this page from time to time to ensure that you continue to agree with the terms of this Policy.

We ask that you read this Policy carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information, and on how to contact us and supervisory authorities in the event you have a complaint.

1. Who We Are. 

TGG collects, uses, and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.

2. The Personal Information We Collect and Use.

• Information Collected by Us.
  1. In the course of operating the Site and tailoring Site content to our visitors, we collect the following personal information when you provide it to us: name; email address and/or phone number; physical address; job application and other data included in a resume, cover letter, or other application materials (“User PI”).
  2. We may also collect your IP address; and/or router information (“Tech PI”).
  3. Through our work with clients and not via our Site, we may also collect your: image; demographic information, such as, without limitation, age, sex, family income, marital status; preferences and shopping habits; and other personal information so long as we have your explicit written consent (“Research PI”).
• Information Collected from Other Sources.
  1. We may also obtain User PI and Research PI from our third-party research platforms and/or clients.
• How we Use Your Personal Information.
  1. We may use the User PI and Tech PI collected on the TGG Site in order to customize the content you see, to serve you targeted advertising through Facebook, Instagram, and/or LinkedIn, to streamline your Site experience, and/or to send you newsletters or e-mails (for individuals located in the E.U., if you have opted in to receiving them).
  2. We may use Research PI to conduct market and industry research for our clients, provided that no Research PI is provided to our clients without your explicit consent. However, our clients may be provided anonymized or aggregate results derived from Research PI.
• Who We Share Your Personal Information With.
  1. We may share your User PI, Tech PI, or Research PI with employees and contractors only on a need-to-know basis in order to (1) perform their necessary job functions, or (2) conduct specific research and analysis functions for client market and consumer research and only in accordance with the consent provided from the data subject.
  2. We may share your Research PI with our clients if we have your explicit consent.
  3. We may share your User PI with Facebook, Instagram, and/or LinkedIn for the purpose of serving targeted advertisements.
  4. We will share personal information with law enforcement or other authorities if required by applicable law.
  5. We do not otherwise share your User PI, Tech PI, or Research PI with any other third parties.
• Whether Information Has to Be Provided by You and Why.
  1. The provision of first name, last name, and email address is required from you to subscribe to our newsletter.
• How Long Your Personal Information Will Be Kept.
  1. We will hold User PI such as, name and email address, and Tech PI until you request that we delete that data.
  2. We will hold Research PI for no longer than three months after the conclusion of the market and consumer research project for which we obtained the Research PI, or in accordance with the explicit consent signed upon providing the Research PI.
• Reasons We Can Collect and Use Your Personal Information.
  1. We rely on your express consent as the lawful basis on which we collect and use your User PI, Tech PI, or Research PI.
  2. We may also process User PI or Research PI for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

3. Consequences of our Use of Your Personal Information.

Where you have provided us User PI (and for individuals located in the E.U., if you have opted in), you will receive our newsletter and email promotions.  You may also receive targeted advertisements from us via Facebook, LinkedIn, and Instagram if we have your User PI.

4. Transfer of Your Information Out of the EEA (for individuals located in the E.U.).

TGG is based in the United States and that’s where we process personal information.  When you visit our Site and provide User PI, Tech PI, and/or Research PI to us, we request your consent to transfer that personal information to the United States.  The United States does not have an adequacy decision from the European Commission, which means that the Commission has not determined that the laws of the United States provide adequate protection for personal information.  Although United States laws do not provide legal protection that is equivalent to EU data protection laws, we safeguard your personal information by treating it in accordance with this Policy.  We also have appropriate security measures in place to protect your personal information in our possession and when we collect, process, or transfer personal information. We also work with vendors under contracts that require them to treat any personal information they process consistent with this Policy.  We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you would like further information please contact us (see “How to contact us” below).  Except as set forth herein or if we have obtained your explicit consent, we will not transfer your personal information outside of the EEA.

5. Your Rights (for individuals located in the E.U.).

Under the General Data Protection Regulation (GDPR), you have a number of important rights free of charge. In summary, those include rights to:

• Access to your personal information and to certain other supplementary information that this Policy is already designed to address;
• Require us to correct any mistakes in your information which we hold;
• Require the erasure of personal information concerning you in certain situations;
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations;
• Object at any time to processing of personal information concerning you for direct marketing;
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
• Object in certain other situations to our continued processing of your personal information; and
• Otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the GDPR.

If you would like to exercise any of those rights, please:

• Email, call, or write to us;
• Let us have enough information to identify you;
• Let us have proof of your identity and address (a copy of your driver’s license or passport and a recent utility or credit card bill);
• Let us know the information to which your request relates.

If you would like to unsubscribe from any email newsletter you can also click on the unsubscribe button at the bottom of an email newsletter. It may take up to 3 days for this to take place.

7. How to Complain (for individuals located in the E.U.).

We hope that we can resolve any query or concern you raise about our use of your information.  The GDPR also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.  Your supervisory authority may be found here.

8. Our Use of Other Information.

• TGG uses cookies to remember certain user information. You may, at any time, disable or refuse to accept cookies by changing the preferences or settings on your web browser. If you choose to disable cookies, you will still be able to use our Site. However, you will not be able to fully take advantage of certain automation and other functionality features available on this Site.  Accepting cookies while on the Site will not put the user at risk for marketing to other sites.
• Web Statistics & Shared Data. We may collect other non-identifiable aggregate information to analyze trends, administer the site, track user movement, and gather broad aggregate demographic information for reporting and sponsorship purposes.  From time to time, we may use non-identifiable aggregate information to better design our Site and to share with select advertising partners, sponsors, and/or affiliates. For example, we may tell an advertiser that X number of individuals visited a certain area on our Site, or that Y number of men and Z number of women filled out our registration form, but, except as otherwise set forth herein, we would not disclose anything that could be used to personally identify those individuals.

9. Children’s Privacy.

Protecting the privacy of children is especially important to us. For that reason, we never collect or maintain information at our Site from those we actually know are under 13, nor do we allow registration of users under the age of 13.  If you are under 13, DO NOT give us any personal information.  If you have reason to believe that a child has provided personal information to TGG without explicit parental consent, contact us at tech@thegaragegroup.com, and we will use commercially reasonable efforts to delete that information from our databases.

10. Changes to This Policy. 

This Policy was published on May 31, 2019 and last updated on May 31, 2019.  We may change this Policy from time to time, when we do we will inform you via a notice on our Site or by email.

11. How to Contact Us.

Any inquiries about this Policy should be directed to TGG at tech@thegaragegroup.com or by mail to:

The Garage Group, Inc.

Attn:  Tech Function Leader

700 W. Pete Rose Way, Suite 333

Cincinnati, OH 45203

12. California – Additional Privacy Rights.

California’s “Shine the Light” law, Civil Code Section 1798.83, allows California residents who are TGG customers to request certain information regarding our disclosure of PII to third parties for direct marketing purposes. Please contact us at tech@thegaragegroup.com to request information as permitted by California law.  When contacting us, please indicate your name, address, email address, and details regarding your specific request, such as the personal information you do not want us to share with suppliers, affiliates, or third parties. The request should be sent to us at tech@thegaragegroup.com or to our mailing address set forth herein, Attn: Privacy, and labeled “California Customer Choice Notice.”  Please allow 30 days for a response. Also, please note that there is no charge for controlling the sharing of your personal information or requesting this notice.