TNS Website Privacy Policy – USA

Updated 1 January, 2023

DEFINITIONS

 In this document:

• “Personal Data” or “Personal Information” means information which identifies or is reasonably capable of being associated with you or your household (or, as applicable, your employer).
• “Privacy Policy” means the current version of this TNS Website Privacy Policy – USA.
• “We” or “TNS” means Transaction Network Services, Inc., a USA-based corporation registered in Delaware, USA under Delaware Registration No. 3053051. Its principal office is located at Suite 100, 10740 Parkridge Blvd., Reston, Virginia, 20191 USA.
• “You” refers to you, acting individually or on behalf of your employer.

 PRIVACY COMMITMENT

We are committed to respecting your personal privacy, to processing your Personal Data in accordance with your consent, and to protecting any Personal Data that we have collected from you. This Privacy Policy is intended to describe processes for collecting, distributing, and protecting Personal Data, as well as your rights with regards to your Personal Data. If you do not agree with any part of this Privacy Policy, please do not use our websites.

This Privacy Policy is intended to apply only to those persons who are residents of the United States of America.

 TYPES OF PERSONAL DATA COLLECTED

 Personal Data collected by us may include the following:

• Contact Information: If you elect to provide us with this information, this may include your name, email address, and telephone number (this may be your personal telephone number or your work telephone number, depending upon which you provide us with).
• Website Usage Information: We may receive information from third-party analytics companies regarding your interaction with our websites. This may include the following (depending upon whether or not you are logged into your Google account): demographic information (including age and gender), interests (as listed in your Google bio), language preference, location, whether you are a new or returning visitor to our websites, how often you have visited in the past, the type of web browser you are using, IP address, your mobile device type, and your mobile device platform (i.e., Android or iOS).
• Employment Related/Job Applicant Information: We collect additional Personal Data from employees and job applicants. This includes information such as résumé or contact information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information.

We may also collect, track, and use various types of data that are aggregated, de-identified, or otherwise not reasonably capable of identifying you or being linked with you. These types of data are not Personal Data.

COLLECTION OF PERSONAL DATA

We may collect Personal Data from you in the following ways:

• Personal Data You Provide:
  • You may give us your Personal Data when you contact us to learn about our products and services, or to address problems with our products and services. This may be via email, text, telephone, or in person at a trade show or industry event or conference.
  • You may give us your Personal Data when you complete forms on our websites.
  • You may give us your Personal Data when you respond to or complete surveys we use for research and quality control purposes. The completion of such surveys is voluntary.
  • You may give us your Personal Data when you take part in discussion boards or engage in other forms of social media or social networking services.
• Personal Data Collected Automatically:
  • We may collect Personal Data about you when you visit our websites, including the website usage information and third-party analytic and tracking information described above.
  • We may use third parties’ analytics and tracking tools, such as Google Analytics and others, to help us track, segment, and analyze usage of the Services, and to help us or those third parties serve more targeted ads to you on the Services and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information and may also combine such information with information that they collect from other sources. To learn more about your choices relating to advertising tracking, please see the “Cookies” section below.
• Personal Data Received from Other Third Parties
  • We may receive information about you from other trusted third-party sources to update or supplement the Personal Data you have provided or that we have collected from you. This may include, for example, information from our parent, subsidiary or affiliate companies, partners and service providers (including, for example, business partners, analytics vendors, advertising campaigns, and search information providers).
• Children’s Personal Data
  • Our products and services, as well as our websites, are not directed to nor intended for use by minors. We do not knowingly collect any Personal Data from children under the age of 16.

 COOKIES

 Cookies are small text files placed on your device to store data. We use cookies and similar technologies for storing your preferences and settings, enabling you to sign in, providing advertising, combating fraud, and fulfilling other legitimate business purposes. Sometimes, we also use web beacons to gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third party providers. Those third party providers may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests.

• Collection of Cookies: Our websites may place cookies on your computer when you visit them (or third-party companies with whom we have a trusted relationship may place a cookie on your system via our websites). You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. We recommend that you allow the use of cookies when visiting our websites in order to enhance your experience:
  • Cookies allow you to get the best experience and may allow additional functionality (such as social media sharing buttons, polls, etc.).
  • Cookies help us to improve our websites by understanding how they are used, including:
    • Which pages are most popular;
    • Which pages are not being used;
    • What information is being searched for;
    • What errors are displayed; and
    • What browsers and devices are being used to access our websites.
  • Categories of Cookies Used: The following categories of cookies are used on our websites:
    • Social Media Cookies: When content from our websites is shared by using a social media sharing button, cookies may be employed for this functionality.
    • Google Analytics Cookies: Google Analytics may set certain cookies, including Analytics, Google Tag Manager, Google Call Tracking, and Google Ad Services. For more information, please visit Google Analytics.
    • WordPress Cookies: When you visit our websites, a WordPress cookie may be placed on your system to indicate what materials you have accessed from our website.
    • Third Party Cookies: Some third parties may employ cookies. These cookies are not used by, nor the responsibility of, TNS.
  • Controlling Cookies: You may control the use of cookies, as it relates to your browsing experience, in the following ways:
    • You may refuse to accept cookies by activating the appropriate setting on your browser. Please refer to your web browser or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences. However, if you select this setting, you may be unable to access certain parts of our websites.
    • Most third-party websites have their own cookie policies. In addition, some services allow you to control cookie use associated with their services across the web (for example, Google and YouTube). You may access the cookie pages of these sites to delete or opt-out of cookies across all websites where their services are used.

At this time, TNS does not respond to Do Not Track (DNT) signals except in jurisdictions where we are required to do so by law.

USE AND SHARING OF PERSONAL DATA

We may use your Personal Data in several ways, including the following:

• Internally and With Other TNS Companies:
  • We may use your Personal Data to conduct our business, including providing products and services to you (including support), performing administrative operations, accounting, risk management, recordkeeping, archiving, systems development and testing, meeting our legal obligations, and staff training. We may also use your Personal Data for internal research, planning, marketing, and product improvement and development purposes.
  • If you have given us your consent, we may use the Personal Data we’ve collected about you to advertise and market to you by sending you information about products and services of TNS or other TNS companies, using various channels such as mail, phone, email, and SMS.
  • We may use your Personal Data, as well as information about you we receive from third-party sources, to help us maintain the accuracy of the information we collect, personalize your experience with our websites, target our communications so that we can inform you of products and services or other offers that may be of interest to you, measure ad quality and responses, and for internal business purposes.
  • We may combine the Personal Data we receive from and about you to the extent permitted by applicable laws. We may also de-identify or aggregate such information such that it is no longer Personal Data.

• Other Sharing of Personal Data: We may share the categories of personal data we obtain about you (as described above) with the categories of third parties described below. We may share your personal data with TNS affiliates and subsidiaries, vendors, partners, and service providers and/or disclose Personal Data we have collected for certain specific reasons, including:
  • with your “opt-in” consent;
  • to external payment systems operators, as necessary to carry out payment and transaction instructions connected with the operation of our business;
  • as required by law, or as required or ordered by a government or regulatory body, agency, or organization;
  • for crime investigation and prevention purposes or to comply with a legal obligation;
  • in connection with actual or prospective legal proceedings to enforce our legal rights;
  • to detect, address, prevent, and protect against fraud or other illegal or unauthorized activities, such as to enforce our terms of use, to conduct data analysis to improve countermeasures against fraud, to protect the security and integrity of our websites, and to protect the property or safety of our business, our assets, and our customers; or
  • to complete due diligence associated with corporate acquisitions and sales, including disclosure to a potential buyer or seller of business or assets, or to a third party that acquires TNS, a TNS operating group, or a portion of the assets of any of the foregoing.
• Sale of Personal Data: TNS does not sell any Personal Data for monetary consideration.

PROCESSING OF PERSONAL DATA

We may store Personal Data at, and transfer Personal Data to, a destination outside the USA in connection with the purposes set forth in this Privacy Policy. This may include storage with or transfer to other TNS companies and/or third-party suppliers. By using our websites, or by providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to the USA and to other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen. Where any such storage or processing takes place, appropriate controls are in place to ensure that your Personal Data is protected. Where we are required to do so by the applicable laws, we ensure that before transferring your personal data outside your country of residence we comply with the requirements of applicable laws.

PROTECTION OF PERSONAL DATA

The security of your personal data is important to us. We maintain reasonable administrative, technical and/or physical safeguards and appropriate security measures to protect Personal Data from loss, misuse or unauthorized access, disclosure, alteration, or destruction of the information you provide.  All of our employees, as well as all of our service providers who have access to Personal Data, are obligated to protect it and keep it confidential. However, we cannot guarantee the security of your Personal Data, as no system or electronic data transmission is completely secure.  If an incident is reported affecting your information, we will investigate and comply with all required reporting obligations.

RETENTION OF PERSONAL DATA

We may store your Personal Data during the period that we provide products and services to you or to your employer. Once our relationship with you has come to an end, we will retain your Personal Data for a period of time that enables us to:

– Maintain business records for analysis and/or audit purposes

– Comply with record retention requirements under the law

– Defend or bring any existing or potential legal claims

– Address any complaints regarding the services

We will delete your Personal Data when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

We may also retain certain information obtained from your Personal Data where such information has been aggregated, de-identified, anonymized, or pseudonymized such that it is no longer capable of identifying you.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

You have choices about how TNS collects and uses your data. You can exercise your data protection rights by contacting TNS as noted in the Contact Information section below. We will respond to you within the time limits established by applicable law.

Namely, you have the following rights in connection with processing of your Personal Data performed by TNS, subject to applicable law:

• access your Personal Data;
• correct the information we hold about you;
• erase or delete your Personal Data;
• restrict our use of your Personal Data;
• object to our use of your Personal Data;
• withdraw your consent for us to use your Personal Data, if applicable;
• receive your Personal Data in a usable electronic format and transmit it to a third party (right to data portability);
• opt out of the processing of your Personal Data for purposes of targeted advertising, certain profiling, or the sale of your Personal Data; and
• lodge a complaint with your local data protection authority

Subject to applicable law, you may appeal our decision with respect to a request you have submitted by contacting TNS as noted in the Contact Information section below.

STATE REQUIRED NOTICES

California: If you are a California resident and have provided us with your Personal Information, you may ask us to refrain from sharing your Personal Information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes. Please tell us your preference by contacting us via the contact information in the “How to Contact Us” section of this Privacy Policy. Scroll down to view our California Consumer Privacy Notice.

CONTACT INFORMATON REGARDING PRIVACY

• How to Contact Us: You may contact us at any time if you have any questions about this Privacy Policy, to exercise your rights regarding your Personal Data, to file a complaint regarding how we process your Personal Data, or for any privacy-related queries. Please direct all queries and questions regarding privacy to our Data Protection Officer at the following email address: privacy@tnsi.com.
• Contacting a Privacy Regulator: If you are not satisfied with our response, you can contact the relevant privacy regulator or agency in your state, or at the federal level, you can contact the Federal Trade Commission.

EXTERNAL WEBSITES

Our websites may contain links to external websites. If you use those links to leave our website and visit a website operated by an entity not within TNS, we have no control over that website, and we cannot be held responsible for the collection, use, or protection of your Personal Data on that external website. If you provide information on and use third party services or websites, the privacy policy and terms of service on those sites are applicable. The collection, protection, use, sharing, processing, and retention practices regarding Personal Data on such external websites may be different than the practices described herein. We encourage you to read the privacy policies of websites that you visit before submitting Personal Data.

PRIVACY POLICY UPDATES

This Privacy Policy is periodically reviewed and updated. The date of the last update to this Privacy Policy appears at the top of this document. We reserve the right to modify this policy at any time without prior notice. When the notice is updated, we will provide information about any substantial changes we have made, as well as the date of the update.

California Consumer Privacy Notice

Last Updated: January 1, 2023

This California Consumer Privacy Notice for California residents (“Notice”) supplements the TNS Privacy Policy and applies only to the Personal Information collected online and offline of California consumers (excluding TNS employees, contractors and other personnel).

This Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and its implementing regulations (collectively, the “CCPA”). Your rights and our obligations under CCPA are explained below.

Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the Last Updated Date of this Notice), the following types of Personal Information:

• Identifiers: Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology, telephone number, online identifier, internet protocol address, email address, account name, and other similar identifiers.
• Additional Data Subject to Cal. Civ. Code § 1798.80: Education, credit card number, debit card number, and other financial information.
• Protected Classifications: Characteristics of protected classifications under California or federal law, such as national origin, age, sex, gender, marital status, religion, ancestry, and veteran status.
• Commercial Information: Commercial information, including records of personal property, products or services
• purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data
• Sensory Information: Audio, electronic, visual, and similar information
• Employment Information: Professional or employment-related information such as résumé or contact information, occupation details, education details, certifications and professional associations, historical compensation details, previous employment details, emergency contact information, and pre-employment screening and background check information, including criminal records information

We may use (and may have used during the 12-month period prior to the Last Updated Date of this Notice) your Personal Information for the purposes described in the TNS Privacy Policy and for the following business purposes:

• Performing services: Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing analytics services, providing storage, or providing similar services
• Marketing: Providing advertising and marketing services
• Auditing: Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
• Short Term Use: Short Term Use: Short-term, transient use such as non-personalized advertising shown as part of your current interaction with us
• Security Purposes: Helping to ensure security and integrity
• Debugging: Debugging to identify and repair errors that impair existing intended functionality
• Internal R&D: Undertaking internal research for technological development and demonstration
• Safety: Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
• Career Opportunities: Managing career opportunities with us
• Business Partners: Managing our relationships with current or prospective partners, corporate customers and vendors and other business partner personnel

We do not collect or process sensitive Personal Information for purposes of inferring characteristics about individuals.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

Retention of Personal Information

We retain Personal Information as described in the “Retention of Personal Data” section of our Privacy Policy.

Sources of Personal Information

During the 12-month period prior to the effective Last Reviewed date of this Notice, we may have obtained Personal Information about you from the following categories of sources:

• Directly from you, such as when you complete forms on our website, attend an event, or interact with social media and/or social networking services
• From your devices, such as when you visit our website
• Our parent, subsidiary and affiliated entities
• Our partners and service providers (including, for example, business partners, analytics vendors, advertising campaigns, and search information providers

Sale or Sharing of Personal Information

We do not sell your Personal Information in exchange for monetary compensation. We may share your Personal Information by allowing certain third parties (such as online advertising services) to collect Personal Information via automated technologies on our websites. This kind of sharing may be considered a “sale” or “sharing” of Personal Information under California law. You have the right to opt out of these types of disclosures of your information.

Disclosure of Personal Information

We may disclose (and may have disclosed during the 12-month period prior to the Last Updated date of this Notice) your Personal Information with certain categories of third parties, including as described in our Privacy Policy and below, including for the business purposes described above.

 

CATEGORIES OF PERSONAL INFORMATION	CATEGORIES OF THIRD PARTIES
Identifiers	–       TNS affiliates and subsidiaries –       Vendors, partners, and service providers –       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants) –       Law enforcement agencies, courts, regulators and government authorities
Additional data subject to Cal. Civ. Code § 1798.80	–       TNS affiliates and subsidiaries –       Vendors, partners, and service providers –       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants) –       Law enforcement agencies, courts, regulators and government authorities
Commercial information	–       TNS affiliates and subsidiaries –       Vendors, partners, and service providers –       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants) –       Law enforcement agencies, courts, regulators and government authorities
Online activity	–       TNS affiliates and subsidiaries –       Vendors, partners, and service providers –       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants) –       Law enforcement agencies, courts, regulators and government authorities
Employment information	–       TNS affiliates and subsidiaries –       Vendors, partners, and service providers –       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants) –       Law enforcement agencies, courts, regulators and government authorities
Geolocation data	–       TNS affiliates and subsidiaries –       Vendors, partners, and service providers –       Corporate business partners (such as parties involved in a transfer of our assets, attorneys and consultants) –       Law enforcement agencies, courts, regulators and government authorities

California Consumer Rights

You have certain choices regarding TNS’ use and disclosure of your Personal Information, subject to relevant exception under applicable law, as described below.

• Access: You may have the right to request, twice in a 12-month period, that we disclose to you the Personal Information we have collected, used, disclosed and sold or shared about you.
• Correction: You have the right to request that we correct the Personal Information we maintain about you, if that information is inaccurate.
• Deletion: You have the right to request that we delete certain Personal Information we have collected from you.
• Opt-Out of Sale or Sharing: You have the right to opt-out of the sale of your Personal Information or the sharing of your Personal Information.
• Shine the Light Request: If you are a California resident and have provided us with your Personal Information, you may ask us to refrain from sharing your Personal Information with third parties, including our affiliates if they are separate legal entities, for direct marketing purposes.

How to Make a Request

You may make a request to exercise your rights under CCPA through any of the following channels:

• Send an email to privacy@tnsi.com
• Call 1-833-613-0205

You may opt out of sale or sharing of personal data by contacting TNS as noted in the Contact Information section of the Privacy Policy. To help protect your privacy and maintain security, we will take steps to verify your identity before actioning your request. If you request access to, correction of or deletion of your Personal Information, we may require you to provide certain information to help us identify you. In addition, if you ask us to provide you with specific pieces of Personal Information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request.

To submit a request as an authorized agent on behalf of a consumer, please contact TNS as noted in the Contact Information section of the Privacy Policy.

If you designate an authorized agent, we may require proof of identity and authority before actioning your request.

Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

 

 

TNS Website Privacy Policy (Europe)

Last Updated: September 2021

Introduction

This TNS Website Privacy Policy (Europe) (European Privacy Policy) has been adopted by Transaction Network Services (“TNS”, “we”, “us”) and the following TNS Group operating entities in Europe (TNS Europe) who are responsible for your personal data:

Country	Company Name	Registered Details	Registered Office
UK	Transaction Network Services (UK) Limited	02952557	Sheffield Business Park, 5 Europa View, Sheffield S9 1XH
Ireland	Transaction Network Services (Ireland) Limited	539032	Suite 2, Third Floor, 23 Shelbourne Road, Ballsbridge, Dublin 4, Ireland
France	Transaction Network Services S.A.S.	RCS Paris 421 285 941	1 rue Saint Georges, 75 009 Paris, France
Italy	Transaction Network Services S.r.	13403090155	Via Pergolesi, 2A 20124 Milano, Italy
Germany	Transaction Network Services GmbH	HRB 48703	Martin-Behaim-Str. 12 D-63263 Neu-Isenburg, Germany.
Spain	Transaction Network Services S.A.U.	A-82959529	Via de las Dos Castillas 33 Atica Edificio 6, Planta 3, 28224 Pozuelo de Alarcon, Madrid.
Netherlands	Transaction Network Services BV	34131544	Prinsengracht 449, 1016 HN Amsterdam, Netherlands
Austria	Transaction Network Services GmbH	FN 270335b	Mariahilfer Straße 32/5. Stock, A-1070 Wien, Austria
Sweden	Transaction Network Services AB	556443-6193	c/o Advice Företagsassistans AB Västmannagatan 10, 1 tr S-111 24 Stockholm
Poland	Transaction Network Services sp. z o.o.	526-286-44-19	ul. Grzybowska 5A, 00-132 Warszawa, Poland

The European Privacy Policy applies to applicable to individuals who reside in the European Economic Area (EEA), the United Kingdom (UK) and Switzerland and their respective personal data.

TNS Europe may amend the European Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business.

For the purposes of this European Privacy Policy, “TNS Group” means the relevant TNS Europe operating entities specified above or any other TNS Group affiliate of the following TNS Group parent company:

Country	Company Name	Registered Details	Registered Office
USA	Transaction Network Services Inc.	Delaware Corporation	10740 Parkridge Blvd., Suite 100, Reston, Virginia 20191.

 

TNS EUROPE PRIVACY COMMITMENT

TNS Europe (and each of the TNS Group operating companies in Europe as listed above) are committed to respecting your personal privacy, protecting the security of any personal data that we collect and ensuring that your personal data is processed in accordance with applicable data protection law.

PERSONAL DATA – COLLECTION, TYPE OF DATA AND PURPOSE

 How we collect personal data

We will collect personal data about you when you contact us by phone, email or otherwise. Such collection of personal data may include:

• Contact and Other Forms – personal data that you provide by filling in contact or other forms on our websites e.g. in order to create an account or make an enquiry.
• personal data you provide when you contact us about our products and services and/or problems with such products/services;
• personal data that we collect when you voluntarily complete surveys that we use for research and quality control purposes (subject to the caveat that you don’t need to respond to such surveys);
• personal data that you provide when you take part in our discussion boards or other forms of social media that are linked to our websites;
• personal data that you provide TNS Europe employees at trade shows, industry forums or similar types of events;
• competitions and surveys – if you enter any competitions or surveys, we capture your name and contact information so we can contact you if you’re the winner. We’ll ask for your consent to process your data for this purpose and any other purposes when you enter any surveys online. You can withdraw your consent at any time by writing to or sending an email to our Data Protection Officer (see details above);
• personal data provided to us by your employer, where we are providing your employer with a product or service for which you are the point of contact
• personal data collected automatically
  • we may collect Personal Data about you when you visit our website – the information collected includes the website usage information (such as traffic data, location data and weblogs) and third-party analytic and tracking information described above:
  • we use third parties’ analytics and tracking tools, such as Google Analytics and others, to help us track, segment, and analyze usage of the Services, and to help us or those third parties serve more targeted ads to you on the Services and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information and may also combine such information with information that they collect from other sources. For further information about automatic collection of data, please refer to Cookies section below.

In addition, we also collect information:

• from publicly available sources, e.g. public registers, professional networking and social medial sites;
• directly from third parties e.g. customer due diligence providers, credit reference agencies, companies who operate public relations or business development databases;
• from third parties with your consent;
• via our or third party IT systems, such as CCTV, access control systems, communications systems, emails and instant messaging systems.

What personal data we collect

Depending on the circumstances, the personal data that we collect about you may include:

• your name;
• work and (as applicable) residential address;
• date of birth;
• personal and work email address;
• personal and work phone number;
• your professional online presence, e.g. LinkedIn profile;
• personal data collected automatically by our websites and by cookies used on our websites – such personal data includes your IP address, website usage information and third-party analytic and tracking information described above; and
• any further personal data required as part of the providing products and services to you or your employer.

The purposes for collecting personal data

We may use and disclose personal information for the following purposes.

• Provision of products and services and/or resolution of queries
• Complying with legislative and regulatory requirements.
  C.19.09 Website Privacy Policy (EU) incl. Coookies_(22.09.2021 PM Updates)(126635923.1)(Grammatical errors rectified) FINAL .docx
• Conducting our business, including performing our administrative operations, accounting, risk management, record keeping, archiving, systems development and testing, and staff training.
• For marketing and business development purposes to: (a) communicate information about our products and services or third party products or services that may be of interest to you (unless you have asked us not to)(b) for our internal administrative, research, planning, marketing and product development (c) to analysis and evaluate the interactions between us and our clients (d) to host or facilitate events and meetings; any other purpose relevant to our client’s needs, or our own internal business requirements.

COOKIES

What are Cookies:

Cookies are small text files that are placed on your computer or mobile device by websites that you visit to identify your browser or to store information or settings in your browse. They are widely used in order to make websites work, or work more efficiently, as well as to provide web services and functionalities for users

 How we use Cookies

We recommend that you allow the use of cookies when visiting our websites in order to enhance your experience.

We use cookies specifically to:

• Allow you to get the best experience and may allow additional functionality (such as social media sharing buttons, polls etc.).
• Help us to improve our websites by understanding how they are used, including:
  • Which pages are most popular;
  • Which pages are not being used;
  • What information is being searched for;
  • What errors are displayed; and
  • What browsers and devices are being used to access our websites.

Categories of Cookies

The following categories of cookies are used on our websites:

• Strictly necessary cookies – these cookies are essential in order to enable you to access and use the features/services on our website. Without these cookies, such features/services cannot be accessed or used. This category of cookies cannot be disabled.
• Social Media Cookies: When content from our websites is shared by using a social media sharing button, cookies may be employed for this functionality.
• Google Analytics Cookies: Google Analytics may set certain cookies, including Analytics, Google Tag Manager, Google Call Tracking, and Google Ad Services. For more information, please visit Google Analytics.
• WordPress Cookies: When you visit our websites, a WordPress cookie may be placed on your system to indicate what materials you have accessed from our website.
• Other third party Cookies: Some third parties may employ cookies. These cookies are not used by, nor the responsibility of, TNS.

How to control use of Cookies

You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings.  The following are ways in which You may control the use of cookies, as it relates to your browsing experience:

• You may refuse to accept cookies by activating the appropriate setting on your browser. Please refer to your web browser or operating system’s website (including the “Help” section within your browser) for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences. However, if you select this setting, you may be unable to access certain parts of our websites.
• Most third-party websites have their own cookie policies. In addition, some services allow you to control cookie use associated with their services across the web (for example, Google – https://policies.google.com/technologies/partner-sites). You may access the cookie pages of these sites to delete or opt-out of cookies across all websites where their services are used.
• For additional information about managing cookies and their use, you may want to visit the independent site such as https://allaboutcookies.org/.

DIRECT MARKETING AND YOUR MARKETING PREFERENCE CONTROLS

We may use your personal data to send you marketing offers and news about our products and services that we believe will be of interest to you, using various channels such as mail, phone, email and SMS. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.

How you can manage your marketing preferences –  To protect privacy rights and to ensure you have control over how we manage marketing with you:

• we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
• you can ask us to stop direct marketing at any time – you can ask us to stop sending email marketing, either (a) by following the ‘unsubscribe’ link which you will find in all the email marketing messages we send you or (b) by contacting the Data Protection Officer of the TNS Group at: privacy@tnsi.com. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email); and
• you can change the way in which your browser manages cookies – you can change marketing preferences on your browser settings.

THE LEGAL BASIS FOR USING YOUR PERSONAL DATA

We will only collect, use and share your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• consent– you have provided your consent to our use (e.g. where you provide us with marketing consents or opt-in to optional additional services or functionality on our websites);
• performance of contract – our use is necessary to perform a contract or take steps to enter into a contract with you (e.g. providing you with our services or creating your user account);
• legitimate purpose -our use is in our legitimate interest as a commercial organisation, subject to your interests and fundamental rights. Where we process personal data on the legal basis of legitimate interests we have determined, acting reasonably and considering the circumstances, that we are able to do so after carrying out a balancing exercise to make sure that our legitimate interests are not overridden by your interests, right and freedoms. Where we rely on this legal basis, (a) we process the data only to the extent that it is necessary for the relevant purpose and (b) the relevant processing activities can be reasonably expected. The legitimate interests we pursue are, (1) to provide our services to our clients (2) to promote our business and our products and services (3) to provide our website visitors with a good level of service (4) for security and to protect our rights, property, and business and cooperate, where required, with law enforcement authorities (5) for the protection of our staff, customers and others (6) for crime prevention, fraud protection and credit risk reduction. In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing (see section below titled “Your Right and Choices”);
• legal or regulatory compliance – our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we have (e.g. the disclosure of information to law enforcement or tax authorities).

PROTECTION AND SECURITY OF YOUR PERSONAL DATA

We are committed to ensuring your personal data is protected and held securely. However, the internet is not a secure medium and we can’t accept responsibility for the security of an email during transmission or for non-delivery of that email.

We’ve put security policies, rules, other organisational and technical measures in place to protect the personal data that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification, and
• unlawful destruction or accidental loss.

SHARING PERSONAL DATA WITH SERVICE PROVIDERS, REGULATORS AND OTHER THIRD PARTIES

1. Within TNS Group – We will share your personal data with other TNS Group members where such disclosure is necessary to provide you with our services or to manage our business. Such TNS Group members include the any TNS Europe operating entities listed in the section titled “Information” above. We have put appropriate measures in place to ensure that all TNS Group members treat your personal data as confidential and have adequate measures in place to protect your personal data.
2. With service providers – We work with carefully selected service providers that carry out certain functions on our behalf. These include companies that help us with:
   • third party telecommunication network and service providers in connection with the services and that we provide;
   • third party technology and other service/equipment providers in connection with the services and equipment that we provide; and
   • equipment maintenance providers.
   We only share the appropriate level of personal data necessary to enable our service providers to carry out their services and we require them to keep the information safe, confidential and protected at all times. Our service providers are under contractual obligations to only act on our instructions and not use your personal data for their own purposes.
3. Additional data sharing – Other than the circumstances detailed above, we won’t disclose your personal data to any third parties, except:
   • to the extent that we are required to do so by law, by a government or regulatory body or by a law enforcement agency, or for crime prevention purposes (including financial crime protection);
   • in connection with any legal proceedings (including prospective legal proceedings);
   • in order to establish or defend our legal rights;
   • in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; or
   • if we, or substantially all of our assets, are acquired by a third party, we may disclose your personal data to a potential or actual third party purchaser in connection with the acquisition

PERSONAL DATA PROCESSED OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)

TNS Group operates on a global basis and accordingly your personal data may be transferred to and stored outside the European Economic Area (EEA), in connection with the above purposes. This could be to other TNS Group companies  or to service providers working on our behalf.

TNS will take appropriate steps to ensure that where any such transfers take place, adequate controls  will be put in place to ensure that this is done in accordance with applicable law and carefully managed to protect your privacy rights and interests. To this end,

• we ensure transfers within TNS Europe and other TNS Group entities outside of the EU will be covered by an agreement entered into by relevant members of TNS Group (an intra-group agreement) incorporate Standard Contractual Clauses (SCCs) which contractually obliges each member to ensure that personal data receives an adequate and consistent level of protection wherever it is transferred within TNS Group;
• where we transfer personal data outside TNS Group, we will obtain contractual commitments from them to protect your personal data, such as the adoption of agreements containing the SCCs; or
• where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal data are disclosed.

You have a right to contact us at privacy@tnsi.com (or alternatively at the address stated in the section above titled Contact Us) for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal data when this is transferred as mentioned above.

RETENTION OF PERSONAL DATA

We will store your personal data for as long as is reasonably necessary for the purposes for which it was collected, as explained in this European Privacy Policy. The length of time your Personal Information is retained depends on the purpose(s) for which it was collected, how it is used, and the requirements to comply with applicable data protection laws.

In some circumstances we may store your personal data for longer periods of time. These circumstances include without limitation: (a) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements; and (b)  so that we have an accurate record of your dealings with us in the event of any complaints, challenges, or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.

YOUR RIGHTS AND CHOICES

You have a number of rights under the data protection laws with regard to your personal data, including without limitation:

• the right to be informed about the personal data we hold about you
• the right to access the personal data we hold on you and information about how we process your data.;
• the right to have any inaccurate or misleading personal data corrected.;
• the right to have any out of date personal data deleted (if we do not have a legal basis for retaining your information);
• the right to restrict or object to any processing (unless we have legitimate grounds for continue to process your personal data)
• the right to object or withdraw your consent to your personal data being used to send you marketing material (see section titled Direct Marketing and Your Marketing Preference Controls above for further details).

To exercise any of these rights, please contact our Data Protection Officer at at privacy@tnsi.com (or alternatively at the address stated in the section above titled Contact Us). We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

 Contact us:

 If you have any data protection related questions, concerns, complaints, believe we have not processed your personal data in accordance with our privacy obligations, and/or if you wish to exercise your rights, please contact our Data Protection Officer:

 Data Protection Officer,

Transaction Network Services (Europe)
Sheffield Business Park,
5 Europa View,
Sheffield S9 1XH

Email: privacy@tnsi.com

MAKING A COMPLAINT

 If you have any complaints (including where you consider that there has been a breach of any data protection laws), we encourage you to first contact our Data Protection Officer (see section above titled Contact Us for contact details). We will investigate and attempt to resolve complaints and dispute and will make every reasonable effort to honour your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.

In addition, you have a right to lodge a complaint with your supervisory authority(which is local to your place of habitual residence). For example: the Information Commissioner’s Office or ICO is the UK supervisory authority for UK residents. Details of other European supervisory authorities can be found at: https://edpb.europa.eu/about-edpb/board/members_en

TNS Website Privacy Policy – Asia Pacific

This Privacy Policy applies to the Transaction Network Services entities outlined below, “TNS” or “we” or “our”, as relevant.

1. In Australia: Transaction Network Services Australia Pty Limited
2. In Hong Kong: Transaction Network Services  HK Pte Limited
3. In India: Transaction Network Services (India) Private Limited
4. In Japan: TNS Japan K.K.
5. In South Korea: Transaction Network Services Korea YH
6. In Malaysia: Transaction Network Services (Malaysia) Sdn. Bhd,
7. In New Zealand: TRANSACTION NETWORK SERVICES NZ LIMITED
8. In the Philippines: Transaction Network Services Phl,Inc.
9. In Singapore: Transaction Network Services SG Pte Limited
10. In Sri Lanka: Transaction Network Services Lanka (Private) Limited
11. In Taiwan: Transaction Network Services Taiwan Limited
12. In Thailand: TRANSACTION NETWORK SERVICES (Thailand) LIMITED

TNS Privacy Commitment

We are committed to respecting personal privacy.   This policy describes how we collect, use, hold and disclose personal information

What is personal information

Personal information is information or an opinion about an identified or reasonably identifiable individual, whether or not the information or opinion is true and whether or not the information is recorded in a material form.

The information that we collect

We may collect or receive the following kinds of personal information.

1. Customer information:  This includes information about current or potential customers that we receive when you interact with us (e.g. if you’re establishing a new service), or that we obtain from an outside source like marketing mailing lists and public information or information received from partners or affiliates.  The kinds of customer information that TNS collects can include names, telephone numbers and email addresses, along with business contact details which are not personal.
2. Website usage information: We may receive information that you provide by filling in forms on the TNS website www.tnsi.com.  If you contact us we will keep a record of that correspondence.  We also collect details of your visits to www.tnsi.com including, but not limited to, traffic data, location data, weblogs and other communication data.
3. IP address: We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information.  This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
4. Cookies: We may, depending on which parts of the site you access, obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us to store information about your preferences, and so allow us to customise our site according to your individual interests and recognise you when you return to our site. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

TNS does not collect, or otherwise have access to, personal information sent or received by its customers in the course of them using TNS’ processing technology solutions (Transactional Information).

How we use personal information

We may use and disclose personal information for the following purposes.

1. Complying with legislative and regulatory requirements.
2. Conducting our business, including performing our administrative operations, accounting, risk management, record keeping, archiving, systems development and testing, and staff training.
3. Any purpose relevant to our client’s needs, or our own internal business requirements.
4. In relation to customer information:
   1. To communicate information about our products and services or third party products or services that may be of interest to you.
   2. For our internal administrative, research, planning, marketing and product development.

When we may disclose personal information

We may disclose your information to other entities within the TNS corporate group.  Subject to what is permitted by law, we may also disclose your information:

1. to our agents, contractors and external advisers whom we engage from time to time to carry out, or advise on, our functions     and activities;
2. to regulatory bodies, government agencies, law enforcement bodies and courts where we are required by law to do so;
3. to external payment systems operators;
4. to any person to the extent necessary, in our view, in order to carry out your payment or transactional instructions, or to           enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of TNS our customers or     others; or
5. if we buy or sell any business or assets, or if TNS or its assets are acquired by a third party, personal information may be transferred as a business asset.

Overseas disclosure

TNS is a global provider of electronic transaction and communication solutions.  We may use other operations of TNS which are located overseas, or trusted third party data management providers in relation to storage and protection of personal information.

In particular, but without limitation, customer information may be transferred to Transaction Network Services, Inc. and any of its subsidiaries.

If we provide personal information to an overseas TNS entity or third party, we will take reasonable steps to ensure that the recipient will be subject to laws or obligations substantially similar to those in the country in which the information was collected.

Access to personal information

If you wish to access or update your personal information, you may request your details by writing to the privacy officer, TNS at privacyofficer@tnsi.com.

In relation to transactional information, TNS does not collect this information.  Access to such information is best gained via the relevant financial institution, card or account provider, or merchant through which a transaction was processed.

Under certain circumstances, we may not be able to disclose what personal information we hold about you. This includes where:

1. it would have an unreasonable impact on the privacy of other individuals;
2. the information relates to legal proceedings with you;
3. the information would reveal a commercially sensitive decision-making process; or
4. we are prevented by law from disclosing the information, or providing access would prejudice certain investigations.

We may charge you a fee for accessing your personal information depending upon the circumstances. You will be advised at the time of your request of any applicable fee.

Security of personal information

TNS maintains strict procedures and standards and takes all reasonable care to prevent unauthorised access to, and modification and disclosure of, your personal information.

TNS will protect any personal information it holds against misuse or loss.  If TNS no longer needs the personal information, we will take steps to either destroy the information or de-identify it.

Complaints

If you consider a breach of a privacy law has occurred, we invite you to write to the privacy officer of TNS at privacyofficer@tnsi.com.  We will make every effort to resolve your complaint internally.

If you are in Australia and are dissatisfied with the resolution we offered you, you may file a complaint with the Office of the Australian Information Commissioner.  The Commissioner can be contacted on 1300 363 992 or by email enquiries@oaic.gov.au

Changes to this policy

TNS may vary this policy from time to time.  If we change the policy, we will post the revised policy as soon as it is completed.  We do not have to provide you with notice of changes to the policy.  We encourage you to periodically review our privacy policy for any changes.

TNS Website Privacy Policy – Rest of the World

Updated 08 November 2021

DEFINITIONS

In this document:

• “Personal Data” means information which identifies or is reasonably capable of being associated with you or your household (or, as applicable, your employer).
• “Privacy Policy” means the current version of this TNS Website Privacy Policy.
• “We” or “TNS” means Transaction Network Services, Inc., a USA-based corporation registered in Delaware, USA under Delaware Registration No. 3053051. Its principal office is located at Suite 100, 10740 Parkridge Blvd., Reston, Virginia, 20191 USA. TNS has offices in various regions of the world. Please check our websites for more information on our office locations.
• “You” refers to you, acting individually or on behalf of your employer.

PRIVACY COMMITMENT

We are committed to respecting your personal privacy, to processing your Personal Data in accordance with your consent, and to protecting any Personal Data that we have collected from you. This Privacy Policy is intended to describe processes for collecting, distributing, and protecting Personal Data, as well as your rights with regards to your Personal Data. If you do not agree with any part of this Privacy Policy, please do not use our websites.

If you are a resident of Europe, the Asia-Pacific Region, or the USA, please see our websites for the Privacy Policy specific to your region. This Privacy Policy is intended to apply to those persons who are residents of other parts of the world.

TYPES OF PERSONAL DATA COLLECTED

Personal Data collected by us may include the following:

• Contact Information: If you elect to provide us with this information, this may include your name, email address, and telephone number (this may be your personal telephone number or your work telephone number, depending upon which you provide us with).
• Website Usage Information: We may receive information from third-party analytics companies regarding your interaction with our websites. This may include the following (depending upon whether or not you are logged into your Google account): demographic information (including age and gender), interests (as listed in your Google bio), language preference, location, whether you are a new or returning visitor to our websites, how often you have visited in the past,
  the type of web browser you are using, your mobile device type, and your mobile device platform (i.e., Android or iOS).
• Job Applicant Information: We collect additional Personal Data from job applicants. For information on our collection, use, sharing, and processing of Personal Data collected from Job Applicants, please see the TNS Job Applicant Privacy Policy available in the Careers section of our websites.

We may also collect, track, and use various types of data that are aggregated, de-identified, or otherwise not reasonably capable of identifying you or being linked with you. These types of data are not Personal Data.

COLLECTION OF PERSONAL DATA

We may collect Personal Data from you in the following ways:

• Personal Data You Provide:
  • You may give us your Personal Data when you contact us to learn about our products and services, or to address problems with our products and services. This may be via email, text, telephone, or in person at a trade show or industry event.
  • You may give us your Personal Data when you complete forms on our websites.
  • You may give us your Personal Data when you respond to or complete surveys we use for research and quality control purposes. The completion of such surveys is voluntary.
  • You may give us your Personal Data when you take part in discussion boards or engage in other forms of social media.
• Personal Data Collected Automatically:
  • We may collect Personal Data about you when you visit our websites, including the website usage information and third-party analytic and tracking information described above.
  • We may use third parties’ analytics and tracking tools, such as Google Analytics and others, to help us track, segment, and analyze usage of the Services, and to help us or those third parties serve more targeted ads to you on the Services and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information and may also combine such information with information that they collect from other sources. To learn more about your choices relating to advertising tracking, please see the “Cookies” section below.
• Personal Data Received from Other Third Parties
  • We may receive information about you from other trusted third-party sources to update or supplement the Personal Data you have provided or that we have collected from you. This may include, for example, information from our partners and service providers (including, for example, business partners, analytics vendors, advertising networks, and search information providers).
• Children’s Personal Data
  • Our products and services, as well as our websites, are not directed to nor intended for use by minors. We do not knowingly collect any Personal Data from children under the age of 16.

COOKIES

• Collection of Cookies: Our websites may place cookies on your computer when you visit them (or third-party companies with whom we have a trusted relationship may place a cookie on your system via our websites). You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Services or take full advantage of all of our offerings. We recommend that you allow the use of cookies when visiting our websites in order to enhance your experience:
  • Cookies allow you to get the best experience and may allow additional functionality (such as social media sharing buttons, polls, etc.).
  • Cookies help us to improve our websites by understanding how they are used, including:
    • Which pages are most popular;
    • Which pages are not being used;
    • What information is being searched for;
    • What errors are displayed; and
    • What browsers and devices are being used to access our websites.
• Categories of Cookies Used: The following categories of cookies are used on our websites:
  • Social Media Cookies: When content from our websites is shared by using a social media sharing button, cookies may be employed for this functionality.
  • Google Analytics Cookies: Google Analytics may set certain cookies, including Analytics, Google Tag Manager, Google Call Tracking, and Google Ad Services. For more information, please visit Google Analytics.
  • WordPress Cookies: When you visit our websites, a WordPress cookie may be placed on your system to indicate what materials you have accessed from our website.
  • Third Party Cookies: Some third parties may employ cookies. These cookies are not used by, nor the responsibility of, TNS.
• Controlling Cookies: You may control the use of cookies, as it relates to your browsing experience, in the following ways:
  • You may refuse to accept cookies by activating the appropriate setting on your browser. Please refer to your web browser or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or controlling your tracking preferences. However, if you select this setting, you may be unable to access certain parts of our websites.
  • Most third-party websites have their own cookie policies. In addition, some services allow you to control cookie use associated with their services across the web (for example, Google and YouTube). You may access the cookie pages of these sites to delete or opt-out of cookies across all websites where their services are used.
  • For additional information about cookies and their use, you may wish to visit third-party pages which describe them (for example, visit All About Computer Cookies, or lookup “HTTP Cookies” on Wikipedia.

USE AND SHARING OF PERSONAL DATA

We may use your Personal Data in several ways, including the following:

• Internally and With Other TNS Companies:
  • We may use your Personal Data to conduct our business, including performing administrative operations, accounting, risk management, recordkeeping, archiving, systems development and testing, and staff training. We may also use your Personal Data for internal research, planning, marketing, and product improvement and development purposes.
  • If you have given us your consent, we may use the Personal Data we’ve collected about you to send you information about products and services of TNS or other TNS companies, using various channels such as mail, phone, email, and SMS.
  • We may use your Personal Data, as well as information about you we receive from third-party sources, to help us maintain the accuracy of the information we collect, personalize your experience with our websites, target our communications so that we can inform you of products and services or other offers that may be of interest to you, measure ad quality and responses, and for internal business purposes.
  • We may combine the Personal Data we receive from and about you. We may also de-identify or aggregate such information such that it is no longer Personal Data.
• Other Sharing of Personal Data: We may disclose Personal Data we have collected for certain specific reasons, including:
  • to external payment systems operators, as necessary to carry out payment and transaction instructions connected with the operation of our business;
  • as required by law, or as required or ordered by a government or regulatory body, agency, or organization;
  • for crime investigation and prevention purposes;
  • in connection with actual or prospective legal proceedings to enforce our legal rights;
  • to detect, address, prevent, and protect against fraud or other illegal or unauthorized activities, such as to enforce our terms of use, to conduct data analysis to improve countermeasures against fraud, to protect the security and integrity of our websites, and to protect the property or safety of our business, our assets, and our customers; or o to complete due diligence associated with corporate acquisitions and sales, including disclosure to a potential buyer or seller of business or assets, or to a third party that acquires TNS, a TNS operating group, or a portion of the assets of any of the foregoing.
• Sale of Personal Data: TNS does not sell any Personal Data.

PROCESSING OF PERSONAL DATA

We may store Personal Data at, and transfer Personal Data to, a destination outside your region in connection with the purposes set forth in this Privacy Policy. This may include storage with or transfer to other TNS companies and/or third-party suppliers. By using our websites, or by providing us with any information, you consent to the collection, processing, maintenance and transfer of such information in and to your region and to other applicable territories in which the privacy laws may not be as comprehensive as, or equivalent to, those in the country where you reside and/or are a citizen. Where any such storage or processing takes place, appropriate controls are in place to ensure that your Personal Data is protected.

PROTECTION OF PERSONAL DATA

We take precautions to protect the Personal Data we collect and store. All of our employees, as well as all of our service providers who have access to Personal Data, are obligated to protect it and keep it confidential. However, no system or electronic data transmission is completely secure. If you give us your Personal Data, you do so at your own risk. We expect that you will use appropriate security measures to protect your Personal Data.

RETENTION OF PERSONAL DATA

We may store your Personal Data during the period that we provide products and services to you or to your employer, and for up to seven years after such relationship ends. This is to ensure that we can comply with contractual obligations relating to the provision of those products and services and comply regulatory and legislative requirements. We may also retain certain information obtained from your Personal Data where such information has been aggregated, de-identified, anonymized, or pseudonymized such that it is no longer capable of identifying you.

CONTACT INFORMATION REGARDING PRIVACY

• Contacting Us: You may contact us at any time if you have any questions about this Privacy Policy, to exercise your rights regarding your Personal Data, to file a complaint regarding how we process your Personal Data, or for any privacy-related queries. Please direct all queries and questions regarding privacy to our Data Protection Officer at the following email address:privacy@tnsi.com
• Contacting a Privacy Regulator: If you are not satisfied with our response, you can contact the relevant privacy regulator or agency in your region.

EXTERNAL WEBSITES

Our websites may contain links to external websites. If you use those links to leave our website and visit a website operated by an entity not within TNS, we have no control over that website, and we cannot be held responsible for the collection, use, or protection of your Personal Data on that external website. The collection, protection, use, sharing, processing, and retention practices regarding Personal Data on such external websites may be different than the practices described herein.

PRIVACY POLICY UPDATES

This Privacy Policy is periodically reviewed and updated. The date of the last update to this Privacy Policy appears at the top of this document. We reserve the right to modify this policy at any time without prior notice. 

TNS Job Applicant Privacy Policy – USA

Updated 08 November 2021

DEFINITIONS

In this document:

• “Personal Data” means information which identifies or is reasonably capable of being associated with you or your household (or, as applicable, your employer).
• “Job Applicant Privacy Policy” means the current version of this TNS Job Applicant Privacy Policy – USA.
• “We” or “TNS” means Transaction Network Services, Inc., a USA-based corporation registered in Delaware, USA under Delaware Registration No. 3053051. Its principal office is located at Suite 100, 10740 Parkridge Blvd., Reston, Virginia, 20191 USA.
• “You” means the person who is applying for a job on our websites.

PRIVACY COMMITMENT

We are committed to respecting your personal privacy, to processing your Personal Data in accordance with your consent, and to protecting any Personal Data that we have collected from you. This Job Applicant Privacy Policy is intended to describe processes for collecting, distributing, and protecting Personal Data, as well as your rights with regards to your Personal Data, specifically in connection with your application for a job through our websites. On our websites, you will be required to indicate that you have read and agree with this Job Applicant Privacy Policy before you will be allowed to apply for a job with us.

This Job Applicant Privacy Policy is intended to apply only to those persons who are residents of the United States of America.

TYPES OF PERSONAL DATA COLLECTED

In connection with your application for a job with us, Personal Data collected by us includes information that you voluntarily submit to us, and may include the following:

• Biographical Information: This includes information you provide to us about yourself, including your name, alias(es), former name(s), gender, date of birth, email address, mobile telephone number, home telephone number, address(es), protected classification(s), language proficiencies, and other information required to determine your eligibility and suitability for a job with us, as well as information about you provided to us by your current or former employers, educational institutions, and co-workers.
• Educational Information: This includes information you provide about educational history, such as the names, places, and dates of attendance and graduation of your schools, trade schools, colleges, and universities, as well as the certificates, diplomas, and degrees awarded, as well as information provided to us by your current or former educational institutions.
• Professional Information: This includes information you provide about your employment history, such as the names, places, and dates of former or current employers, the positions you held, professional qualifications (such as licenses, permits, certifications, and memberships relevant to your work history), as well as information provided to us by your current or former employers and co-workers.
• Job Preference Information: This includes information you provide about the geographical locations, positions, and compensation you seek, as well as your willingness to relocate.
• Interview Information: This includes information you provide to us (whether in person, over the phone, in a virtual meeting, on paper, or otherwise) in the process of our interviewing you for a position with us.
• Other Information: This may include any additional information which you voluntarily provide to us, or make available to us through a third party, in the process of your application for a job with us.

COLLECTION OF PERSONAL DATA

Providing Personal Data to us in connection with your application for a job with us is voluntary. However, if you do not provide us with certain information, or do not provide sufficiently detailed information, we may be unable to consider you for a job with us.

To the extent you voluntarily provide us with your Personal Data in connection with your application for a job with us, or make such Personal Data available to us through a third party, we may collect such Personal Data in the following ways:

• Personal Data You Provide: You may give us your Personal Data (as described above) when you contact us to inquire about available jobs; when you apply for a job with us (whether on our websites, via mail, via email, or otherwise); and/or when you interview with us.
• Personal Data Received from Third Parties: We may receive information about you from third parties, including current or former employers, current or former educational institutions, and current or former co-workers.

USE AND SHARING OF PERSONAL DATA

We may use your Personal Data in several ways, including the following:

• • Screening, Recruiting, and Hiring Applicants: We may use your Personal Data to evaluate your eligibility and suitability for one or more positions with us; to schedule and conduct interviews with you; to communicate with you regarding your job application(s); to satisfy our legal obligations (including, for example, our obligations under Equal Opportunity Employment laws); to evaluate and improve our recruiting process; and for routine business purposes.
• Sale of Personal Data: TNS does not sell any Personal Data collected in the job application process.

RETENTION OF PERSONAL DATA

At the time we collect your Personal Data in connection with your application for a job with us, we may store such Personal Data for the purposes of evaluating your eligibility and suitability for one or more positions with us. In addition, after the job application process, we may continue to store such Personal Data for the purposes of evaluating your eligibility and suitability for future positions with us. We may also retain certain information obtained from your Personal Data where such information has been aggregated, de-identified, anonymized, or pseudonymized such that it is no longer capable of identifying you, for the purposes of evaluating and improving our recruiting process.

PROTECTION OF PERSONAL DATA

We take precautions to protect the Personal Data we collect and store. All of our employees, as well as all of our service providers who have access to Personal Data, are obligated to protect it and keep it confidential. However, no system or electronic data transmission is completely secure. If you give us your Personal Data, you do so at your own risk. We expect that you will use appropriate security measures to protect your Personal Data.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

Rights of California Residents (this section applies only to California consumers)

California consumers have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”). Your rights and our obligations under CCPA are explained below.

Access and Disclosure Requests: Under CCPA, California consumers have the right to request, up to two times in a 12-month period, that a business disclose what Personal Data it has collected, disclosed, and sold about them in the 12 months immediately preceding the request. Here are the specific types of information California consumers may request, as well as an explanation of TNS’s practices for each one: The categories and specific pieces of Personal Data that the business collected about them in the preceding 12 months, the business purpose for such collection, and corresponding categories of sources from which the business collected the information.

1. In the last 12 months, TNS has (or may have) collected the following Personal Data:

• • • TNS has (or may have) collected the Personal Data you provide to us, or that you make available to us through a third party, in connection with your application for a job with us as described in the “TYPES OF PERSONAL DATA COLLECTED” AND COLLECTION OF PERSONAL DATA” sections (above).
  • You may send an access request to TNS through the following channels:
    • Send an email toprivacy@tnsi.com
    • Call 1-833-613-0205
    • Visit https://tnsi.com/forms/california-customer-privacy-act-ccpa/

2. The categories of Personal Information, and the categories of third parties to whom the business disclosed their Personal Information in the preceding 12 months, and the business or commercial purpose for such disclosure.

• In the last 12 months, TNS has disclosed no Personal Data in connection with job applications with us to any third parties.

3. The categories of Personal Information and the categories of third parties to whom the business sold their Personal Information in the preceding 12 months, and the commercial purpose for such sale.

• TNS does not sell any Personal Data in connection with the job application process.

Deletion Requests: Under CCPA, California consumers may request that a business delete any Personal Data that the business collected from or about them. Each such request is subject to reasonable verification of the consumer’s identity by the business. Note that there are some reasons a business will not be able to fully address a California consumer’s request, such as if the business needs to complete a transaction for the consumer, to detect and protect against fraudulent and illegal activity, to exercise the business’s rights, for the business’s internal purposes, or to comply with a legal obligation.

• You may send a deletion request to TNS through the following channels:
  • Send an email toprivacy@tnsi.com
  • Call 1-833-613-0205
  • Visit https://tnsi.com/forms/california-customer-privacy-act-ccpa/
• You will need to provide enough information such that TNS can verify your identity. If TNS cannot reasonably verify your identity, your request may be denied.
  Opt-out Requests: Under CCPA, California consumers may direct a business that sells Personal Data about the consumer to third parties not to sell the consumer’s Personal Data.
• TNS does not sell any Personal Data in connection with the job application process. Accordingly, TNS is not required under CCPA to respond to consumer requests to stop selling Personal Data provided by California Consumers in connection with their application for a job with us.

CONTACT INFORMATION REGARDING PRIVACY

• Contacting Us: You may contact us at any time if you have any questions about this Job Applicant Privacy Policy, to exercise your rights regarding your Personal Data, to file a complaint regarding how we process your Personal Data, or for any privacy-related queries. Please direct all queries and questions regarding privacy to our Data Protection Officer at the following email address: privacy@tnsi.com
• Contacting a Privacy Regulator: If you are not satisfied with our response, you can contact the relevant privacy regulator or agency in your state, or at the federal level, you can contact the Federal Trade Commission.

JOB APPLICANT PRIVACY POLICY UPDATES

This Job Applicant Privacy Policy is periodically reviewed and updated. The date of the last update to this Job Applicant Privacy Policy appears at the top of this document. We reserve the right to modify this policy at any time without prior notice.

TNS Job Applicant Privacy Policy (Europe)

Effective: [   30 ] October 2020

1.                   Introduction

1.1                TNS Job Applicant Privacy Policy (Europe) (European Privacy Policy) has been adopted by Transaction Network Services (“TNS”, “we”, “us”) and the following TNS Group operating companies in Europe (“TNS Europe”) who are responsible for your personal data  are committed to protect any personal data that they collect in accordance with applicable privacy legislation.

Country	Company Name	Registered Details	Registered Office
UK	Transaction Network Services (UK) Limited	02952557	Sheffield Business Park, 5 Europa View, Sheffield S9 1XH
Ireland	Transaction Network Services (Ireland) Limited	539032	Suite 2, Third Floor, 23 Shelbourne Road, Ballsbridge, Dublin 4, Ireland
France	Transaction Network Services S.A.S.	RCS Paris 421 285 941	1 rue Saint Georges, 75 009 Paris, France
Italy	Transaction Network Services S.r.l	13403090155	Via Pergolesi, 2A 20124 Milano, Italy
Germany	Transaction Network Services GmbH	HRB 48703	Martin-Behaim-Str. 12 D-63263 Neu-Isenburg, Germany.
Spain	Transaction Network Services S.A.U.	A-82959529	Via de las Dos Castillas 33 Atica Edificio 6, Planta 3,  28224 Pozuelo de Alarcon,  Madrid.
Netherlands	Transaction Network Services BV	34131544	Prinsengracht 449, 1016 HN Amsterdam, Netherlands
Austria	Transaction Network Services GmbH	FN 270335b	Mariahilfer Straße 32/5. Stock, A-1070 Wien, Austria
Sweden	Transaction Network Services AB	556443-6193	c/o Advice Företagsassistans AB Västmannagatan 10, 1 tr S-111 24 Stockholm
Poland	Transaction Network Services sp. z o.o.	526-286-44-19	ul. Grzybowska 5A, 00-132 Warszawa, Poland

 

For the purposes of this European Privacy Policy, “TNS Group” means the relevant TNS Europe operating entities specified above or any other TNS Group affiliate of the following TNS Group parent company:

Country	Company Name	Registered Details	Registered Office
USA	Transaction Network Services Inc.	Delaware Corporation	10740 Parkridge Blvd., Suite 100, Reston, Virginia 20191.

1.2                The European Privacy Policy applies to applicable to individuals who reside in the European Economic Area (EEA), the United Kingdom (UK) and Switzerland and their respective personal data.  The relevant TNS Europe company who collects the data will be the data controller of your personal data.  In addition, where processing of personal data is undertaken by other TNS Europe or TNS Group (for their own independent purposes), these associated companies may be joint controllers of your personal data.

1.3                We hold and process data on all current and former employees, workers, individual contractors, contingent workers, applicants, interview candidates, interns, agency workers, consultants, directors, and members  (“staff” or “you” or “your”), and third parties whose information you provide to us in connection with the employment or other working relationship (e.g. next‑of‑kin, emergency contact information and/or dependents).

1.4                We take your data protection rights and our legal obligations seriously.  Your personal data will be treated in a secure and confidential manner and only as set out below or otherwise notified to you in writing.

1.5                Please read the following carefully to understand our views and practices regarding your personal data and how we treat it.  The following Data Privacy Notice describes the categories of personal data we may process, how your personal data may be processed, for what purposes we process your data and how your privacy is safeguarded in the course of our relationship with you.  It is intended to comply with our obligations to provide you with information about the Company’s processing of your personal data under privacy laws.  It does not form part of your contract of employment or engagement.

1.6                Purely for the purposes of this Data Privacy Notice, references to employment include engagement where you do work for us and you are not an employee.

1.7                TNS Europe may amend the European Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business.

 

2.                 Responsibility for data privacy

2.1                You may contact TNS’s Data Protection Officer (“DPO”) securely and confidentially at any time if you have any concerns about the processing of your personal data or any data protection issue.

Data Protection Officer
Transaction Network Services (Europe)
Sheffield Business Park,
5 Europa View,
Sheffield
S9 1XH

Email: privacy@tnsi.com

 

2.2                If you have any questions regarding the processing of your personal data, please email the Human Resources department at HR-EU@tnsi.com.  If you are aware of an unauthorised disclosure of data or if you believe your privacy rights have otherwise been violated, please contact the Data Protection Officer at privacy@tnsi.com..

 

3.                   Processing of personal data

3.1                The Company collects and processes your personal data for the purposes described in this European Privacy Policy.  Personal data means any information describing or relating to an identified or identifiable individual.  An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

4.                   What data do we process?

4.1                We collect various types of personal data about you for the purposes described in this European Privacy Policy including:

4.1.1                       Personal details: your title and name, birth name, preferred name, any additional names, gender, nationality, second nationality, civil/marital status, date of birth, age, home contact details (eg address, telephone or mobile number, e‑mail), national ID number, immigration and eligibility to work information, driving licence, languages spoken; next‑of‑kin/dependent/emergency contact information, details of any disability and any reasonable adjustments required as a result;

4.1.2                       Recruitment and selection data: skills and experience, qualifications, references, CV and application, record of interview, interview notes and assessment, vetting and verification information (eg results of credit reference check, financial sanction check and a basic disclosure criminal record check relating to unspent convictions where carried out and permitted by applicable law), right to work verification, information related to the outcome of your application, details of any offer made to you;

4.1.3                       Data related to your engagement: contract of employment or engagement, work contact details (eg corporate address, telephone number, e‑mail), employee or payroll number, photograph, work location default hours, default language, time zone and currency for location, your worker ID and various system IDs, your work biography, your assigned business unit or group, your reporting line, your employee/contingent worker type, your hire/contract begin and end dates, terms and conditions of engagement, your cost centre, your job title and job description, your working hours and patterns, whether you are full or part time; your termination/contract end date; the reason for termination; your last day of work; exit interviews, references to be provided to prospective employers, status (active/inactive/terminated); position title; the reason for any change in job and date of change;

4.1.4                       Regulatory data: records of your registration with any applicable regulatory authority, your regulated status and any regulatory certificates and references;

4.1.5                       Remuneration and benefits data: your remuneration information (including salary/hourly plan/contract pay/fees information as applicable, allowances, overtime, bonus and commission plans), payments for leave/absence (eg holiday pay, sick pay, family leave pay), bank account details, grade, national insurance number, tax information, third party benefit recipient information (eg expression of wish and dependents information), details of any benefits you receive or are eligible for, benefit coverage start date, expense claims and payments, loans, deductions, salary sacrifice arrangements, childcare vouchers, share scheme participation, information and agreements;

4.1.6                       Leave data: attendance records, absence records (including dates and categories of leave/time‑off requests and approvals), holiday dates, requests and approvals and information related to family leave (maternity, paternity, adoption, parental, shared parental, dependents), information related to special leave (eg bereavements, jury service, compassionate);

4.1.7                       Absence management data: absence history, fit notes, details of incapacity, details of work impact and adjustments, details of treatment and prognosis, manager and HR communications, return to work interviews, meeting records, medical reports, occupational health reports;

4.1.8                       Flexible working procedure data:  requests, consideration, correspondence, meeting notes and outcome records

4.1.9                       Restructuring and redundancy records: change plans, organisation charts, consultation records, selection and redeployment data;

4.1.10                    Performance management data: colleague and manager feedback; your appraisals and performance review information, outcomes and objectives; talent programme assessments and records; succession plans; formal and informal performance management process records;

4.1.11                    Training and development data: data relating to training and development needs or training received or assessments completed;

4.1.12                    Disciplinary and grievance data: allegations, complaints, investigation and proceeding records and outcomes;

4.1.13                    Health and safety data: health and safety audits, health and safety screening requests and results, risk assessments, incident reports;

4.1.14                    Monitoring data (to the extent permitted by applicable laws): closed circuit television footage, system and building login and access records, keystroke, download and print records, call recordings, data caught by IT security programmes and filters;

4.1.15                    Employee claims, complaints and disclosures information: subject matter of employment or contract based litigation and complaints, pre‑claim conciliation, communications, settlement discussions, claim proceeding records, employee involvement in incident reporting and disclosures;

4.1.16                    Equality and diversity data: where permitted by law and provided voluntarily, data regarding gender, age, race, nationality, religious belief and sexuality (stored anonymously for equal opportunities monitoring purposes);

4.1.17                    Any other persona data which you choose to disclose to Company personnel during the course of your engagement whether verbally or in written form (for example in work emails);

4.1.18                    Informal opinion data generated in the course of your engagement relating to the administration or management of the Company’s relationship with you.

4.2                Certain additional information will sometimes be collected where this is necessary and permitted by local applicable laws.

5.                   Special categories of data

5.1                To the extent permitted by applicable laws the Company collects and processes a limited amount of personal data within the above data listed at 4.1 falling into special categories, sometimes called “sensitive personal data”.  This term means information relating to:

5.1.1                       racial or ethnic origin;

5.1.2                       political opinions;

5.1.3                       religious or philosophical beliefs;

5.1.4                       physical or mental health (including details of accommodations or adjustments);

5.1.5                       trade union membership;

5.1.6                       sex life or sexual orientation;

5.1.7                       biometric and genetic data; and

5.1.8                       criminal records and information regarding criminal offences or proceedings.

 

6.                   How does the Company collect data?

6.1                The Company collects and records your personal data from a variety of sources, but mainly directly from you.  You will usually provide this information directly to your managers or local Human Resources contact or (where applicable) enter it into the relevant systems (where self-service access is available) your participation in HR processes, emails [and instant messages] you send or through verbal information which may be recorded electronically or manually).  In addition, further information about you will come from your managers or Human Resources or occasionally your colleagues.

6.2                We also obtain some information from third parties: for example, references from a previous employer, medical reports from external professionals, information from tax authorities, benefit providers or where we employ a third party to carry out a background check (where permitted by applicable law).

6.3                In some circumstances, data will sometimes be collected indirectly from monitoring devices or by other means (for example, building and location access control and monitoring systems, CCTV, telephone logs and recordings, instant message logs and email and Internet access logs), if and to the extent permitted by applicable laws.  In these circumstances, the data may be collected by the Company or a third-party provider of the relevant service.  This type of data is generally not accessed on a routine basis but access is possible.  Access can occur, for instance, in situations where the Company is investigating possible violations of Company policies such as those relating to travel and expense reimbursement, use of the telephone system and the Internet, or employee conduct generally, or where the data are needed for compliance or billing purposes.  More frequent access to such data may occur incidental to an email surveillance program, if and to the extent permitted by applicable laws.

6.4                Where we ask you to provide personal data to us on a mandatory basis, we will inform you of this at the time of collection and in the event that particular information is required by the contract or statute this will be indicated.  Failure to provide any mandatory information will mean that we cannot carry out certain HR processes.  For example, if you do not provide us with your bank details, we will not be able to pay you.  In some cases, it may mean that we are unable to continue with your employment or engagement as the Company will not have the personal data we believe to be necessary for the effective and efficient administration and management of our relationship with you.

6.5                Apart from personal data relating to you, you may also provide the Company with personal data of third parties, notably your dependents and other family members, for purposes of HR administration and management, including the administration of benefits and to contact your next‑of‑kin in an emergency.  Before you provide such third party personal data to the Company you must first inform these third parties of any such data which you intend to provide to the Company and of the processing to be carried out by the Company, as detailed in this European Privacy Policy.

7.                   What are the purposes for which data are processed?

7.1                Your personal data are collected and processed for business purposes, in accordance with applicable laws and any applicable collective bargaining agreements.  Data may occasionally be used for purposes not obvious to you where the circumstances warrant such use (eg in investigations or disciplinary proceedings).

7.2                We collect and process your personal data for purposes including:

7.2.1                       Recruitment and selection including:

7.2.1.1                  To assess your suitability to work for us including short listing, agreements and interviews;

7.2.1.2                  to conduct pre‑employment checks including verification of your identity, checking your legal right to work and checking references;

7.2.1.3                  to conduct a pre‑employment credit reference check, financial sanction check and a check in relation to suspect criminal activities in order to prevent crime and other unlawful acts and to protect the business and its clients/customers from the risk of dishonesty, malpractice or improper conduct;

7.2.1.4                  to compare you with other applicants and make a decision whether to offer you employment;

7.2.1.5                  to consider any reasonable adjustments either for the recruitment process or if you were to commence employment with us in the event you have a disability;

7.2.1.6                  to make a job offer and provide a contract of employment;

7.2.1.7                  to prepare to bring you on board as an employee where you accept an offer of employment from us.  In this case we will customise to make sense of the information gathered during recruitment for the purpose of your employment and will transfer some of this to our employment systems and files;

7.2.1.8                  to contact you if you are not successful should another potentially suitable vacancy arise during the six months following the completion of the recruitment process for the role you applied for; and

7.2.1.9                  to deal with any query, challenge or request for feedback received in relation to our recruitment decision; training, development, promotion, career and succession planning and business contingency planning;

7.2.2                       providing and administering remuneration, benefits and incentive schemes and reimbursement of business costs and expenses and making appropriate tax and social security deductions and contributions;

7.2.3                       allocating and managing duties and responsibilities and the business activities to which they relate, including business travel;

7.2.4                       identifying and communicating effectively with staff;

7.2.5                       managing and operating appraisal, conduct, performance, capability, absence and grievance related reviews, allegations, complaints, investigations and processes and other informal and formal HR processes and making related management decisions;

7.2.6                       consultations or negotiations with representatives of staff;

7.2.7                       conducting surveys for benchmarking and identifying improved ways of working and employee relations and engagement at work (these will often be anonymous but may include profiling data such as age to support analysis of results);

7.2.8                       processing information about absence or medical information regarding physical or mental health or condition in order to: assess eligibility for incapacity or permanent disability related remuneration or benefits; determine fitness for work; facilitate a return to work; make adjustments or accommodations to duties or the workplace; make management decisions regarding employment or engagement or continued employment or engagement or redeployment; and conduct related management processes;

7.2.9                       for planning, managing and carrying out restructuring or redundancies or other change programmes including appropriate consultation, selection, alternative employment searches and related management decisions;

7.2.10                    operating email, IT, internet, social media, HR related and other company policies and procedures.  To the extent permitted by applicable laws, the company carries out monitoring of the Company’s IT systems to protect and maintain the integrity of the Company’s IT systems and infrastructure; to ensure compliance with the Company’s IT policies and to locate information through searches where needed for a legitimate business purpose;

7.2.11                    satisfying our regulatory obligations to supervise the persons employed or appointed by the Company to conduct business on its behalf, including preventing, detecting and investigating a wide range of activities and behaviours, whether relating to specific business dealings or to the workplace generally and liaising with regulatory authorities;

7.2.12                    protecting the private, confidential and proprietary information of the Company, its employees, its clients and third parties;

7.2.13                    complying with applicable laws and regulation (for example maternity or parental leave legislation, working time and health and safety legislation, taxation rules, worker consultation requirements, other employment laws and regulation to which the Company is subject in the conduct of its business);

7.2.14                    monitoring programmes to ensure equality of opportunity and diversity with regard to personal characteristics protected under applicable anti‑discrimination laws;

7.2.15                    planning, due diligence and implementation in relation to a commercial transaction or service transfer involving the Company that impacts on your relationship with the Company for example mergers and acquisitions or a transfer of your employment under applicable automatic transfer rules;

7.2.16                    for business operational and reporting documentation such as the preparation of annual reports or tenders for work or client team records including the use of photographic images;

7.2.17                    to operate the relationship with third party customer and suppliers including the disclosure of relevant vetting information in line with the appropriate requirements of regulated customers to those customers, contact or professional CV details or photographic images for identification to clients or disclosure of information to data processors for the provision of services to the Company;

7.2.18                    where relevant for publishing appropriate internal or external communications or publicity material including via social media in appropriate circumstances;

7.2.19                    to support HR administration and management and maintaining and processing general records necessary to manage the employment, worker or other relationship and operate the contract of employment or engagement;

7.2.20                    to comply with reference requests where the Company is named by the individual as a referee;

7.2.21                    to set and change access permissions;

7.2.22                    to provide technical support and maintenance for HR information systems;

7.2.23                    to enforce our legal rights and obligations, and for any purposes in connection with any legal claims made by, against or otherwise involving you;

7.2.24                    to comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment), whether within or outside your country; and

7.2.25                    for other purposes permitted by applicable laws, including legitimate interests pursued by the Company where these are not overridden by the interests or fundamental rights and freedoms of staff and where these have been explained to you before the relevant data is collected or the processing is carried out.

7.3                Special categories of data may be collected and processed by the Company for the following purposes:

7.3.1                       Documentation such as work permits, details of residency, proof of citizenship will be processed to assess and review eligibility to work for the Company in the jurisdiction in which you work;

7.3.2                       your racial or ethnic origin, religion, philosophical or political belief, sexual orientation or disability status may be used for the collection of statistical data subject to local laws, or where required to record such characteristics to comply with equality and diversity requirements of applicable local legislation or to keep the Company’s commitment to equal opportunity under review;

7.3.3                       health and medical information may be used to comply with employment, health and safety or social security laws.  For example to provide statutory incapacity or maternity benefits, avoid breaching legal duties to you, to ensure fair and lawful management of your employment, avoid unlawful termination of your employment, to administer the Company’s private medical and long term disability schemes, to make reasonable accommodations or adjustments and avoid unlawful discrimination or dealing with complaints arising in this regard;

7.3.4                       trade union membership may be recorded to ensure that you receive any relevant rights that you may have in connection with any Trade Union membership, as required to enable us to meet our obligations under employment law, or in order to operate trade union subscription check off at your request;

7.3.5                       information regarding your racial or ethnic origin, religion, philosophical or political belief, sexual orientation, sexual life and sexual orientation may be used in the event of a complaint under the Company’s grievance, whistleblowing, anti‑bullying and harassment or similar policies where such characteristics or information are relevant to the particular complaint, in order to comply with employment law obligations.

8.                   Legal bases for processing

8.1                Personal data

8.1.1                       Whenever the Company processes your personal data we do so on the basis of a lawful condition for processing.  Processing of special categories of data is always justified on the basis of an additional lawful condition.

8.1.2                       In the majority of cases, the processing of your personal data will be justified on one of the following bases:

8.1.2.1                  The processing is necessary for compliance with a legal obligation to which the Company is subject (for example, disclosing the information to HMRC, making statutory payments, avoiding unlawful termination, avoiding unlawful discrimination, meeting statutory record keeping requirements or health and safety obligations); or

8.1.2.2                  Where there is no legal obligation we will process your data where the processing is necessary 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 such a contract (for example collecting bank details to pay your salary or processing information to provide you with the contractual benefits you are entitled to).

8.1.2.3                  Where the above two grounds at 8.1.2.1 or 8.1.2.2 do not apply we may process your personal data where the processing is necessary for the legitimate interests pursued by the Company (being those purposes described in the section above), except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data (for example reviewing your performance at work).

8.1.3                       We will on occasion process your personal data for the purpose of legitimate interests pursued by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.

8.1.4                       In exceptional circumstances where we have no legitimate interest in processing but you ask us to process data for a particular purpose we will occasionally carry out the processing on the basis of your consent (for example if you ask us to provide pay information to a bank for a mortgage application made by you). Where we rely on your consent we will make this clear at the time.

8.2                Special categories of data

8.2.1                       The special categories of personal data that may be processed by the Company are set out in this European Privacy Policy.  Where we process special categories of data it will be justified by a condition set out at [8.1.2] above and also by one of the following additional conditions:

8.2.1.1                  The processing is necessary for the purposes of carrying out the obligations and exercising the rights of you or the Company in the field of employment law, social security and social protection law, to the extent permissible under applicable laws;

8.2.1.2                  The processing is necessary for the purposes of preventive or occupational medicine, for the assessment of your working capacity, medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services, to the extent permitted by applicable laws;

8.2.1.3                  The processing is necessary to protect your vital interests or of another person where you are physically or legally incapable of giving consent (for example in exceptional emergency situations, such as a medical emergency);

8.2.1.4                  The processing is necessary for purposes authorised by applicable law.

8.2.1.5                  The processing is necessary for the establishment, exercise or defence of legal claims; or

8.2.1.6                  In exceptional circumstances the processing is carried out subject to your explicit consent (as explained below).

8.2.2                       We will occasionally seek your consent to certain processing which is not otherwise justified under one of the above bases.  If consent is required for the processing in question, it will be sought from you separately to ensure that it is freely given, informed and explicit.  Information regarding such processing will be provided to you at the time that consent is requested, along with the impact of not providing any such consent.  You should be aware that it is not a condition or requirement of your employment to agree to any request for consent from the Company.

8.3                Processing data relating to criminal convictions and offences

• Personal data relating to criminal convictions and offences will only be processed where authorised by applicable laws. For example:

8.3.1                       a criminal record check may be carried out on recruitment or transfer or intermittently where ongoing screening is required where authorised by applicable laws; or

8.3.2                       an allegation of a criminal offence or conviction arising during your relationship with the Company may be processed where required or authorised by applicable law.  For example:

8.3.2.1                  where we have a legal or regulatory requirement to report an offence; or

8.3.2.2                  where applicable laws authorise the Company to process information about the offence (e.g. in a disciplinary process) for the purpose of making decisions regarding your relationship with the Company.

9.                   automated decision making and profiling

Unless written notice is provided on the contrary, no automated decision making or profiling is undertaken on your personal data.

10.                 Retention of personal data

10.1             The Company endeavours to ensure that personal data are kept as current as possible and that irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable.

10.2             The Company’s general approach is to only retain personal data for as long as is required to satisfy the purpose for which it was collected by us or provided by you.  This will usually be the period of your employment/contract with us plus the length of any applicable statutory limitation period following your departure, although some data, such as pension information, may need to be kept for longer.  We may keep some specific types of data, for example, tax records, for different periods of time, as required by applicable law.  However, some personal data may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.

11.                Disclosures of personal data

11.1             Within the Company, your personal data can be accessed by or will be disclosed internally on a need‑to‑know basis to:

11.1.1                    local, regional and global Human Resources, including managers and team members;

11.1.2                    local, regional and executive management responsible for managing or making decisions in connection with your relationship with the Company or when involved in an HR process concerning your relationship with the Company (including, without limitation, staff from Compliance, Legal, Employee Relations and Information Security);

11.1.3                    system administrators; and

11.1.4                    where necessary for the performance of specific tasks or system maintenance by staff in the Company teams such as the Finance and IT Department and the Global HR information systems support team.

11.2             Certain basic personal data, such as your name, location, job title, contact information, employee number and any published skills and experience profile may also be accessible to other employees.  The security measures in place within the Company to protect your data are set out below.

11.3             Your personal data will be accessed by third parties whom we work together with (including without limitation, with Hire Right (background checking) and Cornerstone (application management) and their associated companies and sub‑contractors) for providing us with services, such as hosting, supporting and maintaining the framework of our HR information systems.

11.4             Personal data will also be shared with certain interconnecting systems and local payroll and benefits systems.  Data contained in such systems may be accessible by providers of those systems, their associated companies and sub‑contractors.

11.5             Examples of third parties with whom your data will be shared include tax authorities, regulatory authorities, the Company’s insurers, bankers, IT administrators, lawyers, auditors, investors, consultants and other professional advisors, payroll providers, and administrators of the Company’s benefits programs.  The Company expects such third parties to process any data disclosed to them in accordance with applicable law, including with respect to data confidentiality and security.

11.6             Where these third parties act as a “data processor” (for example a payroll provider) they carry out their tasks on our behalf and upon our instructions for the above-mentioned purposes.  In this case your personal data will only be disclosed to these parties to the extent necessary to provide the required services.

11.7             In addition, we may share personal data with national authorities in order to comply with a legal obligation to which we are subject.  This is for example the case in the framework of imminent or pending legal proceedings or a statutory audit.

12.                Security of data

12.1             The Company is committed to protecting the security of the personal data you share with us.  In support of this commitment, we have implemented appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk.  The Company uses a variety of technical and organisational methods to secure your personal data in accordance with applicable laws.

12.2             If you are in possession of personal data of any kind (e.g. data collected in emails, address books, Excel spreadsheets or contained in curricula vitae or elsewhere) you must ensure that the data are kept in a safe place where unauthorised access cannot occur.  Where data is retained in hard copy, storage in a locked drawer or cabinet, accessible only to authorised individuals, is generally the most effective means of securing the data.  Where data is kept in electronic form, appropriate password protection and appropriately secured areas should be used.

12.3             You should not create, copy or export personal data relating to any other person outside of official company storage locations and systems except where necessary for a specific authorised and lawful purpose under this European Privacy Policy. In this event appropriate measures must be taken to protect the confidentiality and integrity of the data during the processing.  Once the relevant processing is complete, steps should be taken to store or return the relevant data within the official storage locations/systems with all less formally held records (e.g. local folders, hard copies, emails saved outside of formal manged folders) securely erased.

13.                INTERNATIONAL Transfer of Personal Data

13.1             From time to time your personal data (including special categories of personal data) will be transferred to TNS Group associated companies to process for the purposes described in this European Privacy Policy. This will be applicable for example where the relevant company or a manager from that company is responsible for conducting or approving the relevant process or the data is part of a global directory where other individuals need to have access.

13.2             Personal data may also be transferred to third parties (e.g. service providers or regulators as set out above), who may have systems or suppliers located outside the European Union.

13.3             As a result, in some circumstances your personal data will be transferred to countries outside of the country in which you work or outside of the European Union to countries whose data protection laws may be less stringent than yours.

13.4             The Company will ensure that appropriate or suitable safeguards are in place to protect your personal information and that transfer of your personal information is in compliance with applicable data protection laws.

13.5             Where required by applicable data protection laws, the Company has ensured that service providers (including other Company associated companies) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant Company exporter.  You can obtain a copy of any standard contractual clauses in place which relate to transfers of your personal data by contacting HR-EU@tnsi.com.

13.6             TNS Group has an intra‑group data transfer agreement in place which regulates cross‑border transfers of your data within the Group.

13.7             You have a right to request a copy of any data transfer agreement under which your personal data is transferred, or to otherwise have access to the safeguards used.  Any data transfer agreement made available to you may be redacted for reasons of commercial sensitivity.

14.                Your rights as a data subject

14.1             Right to access, correct and delete your personal data

14.1.1                    The Company aims to ensure that all personal data are correct.  You also have a responsibility to ensure that changes in personal circumstances (for example, change of address and bank accounts) are notified to the Company so that we can ensure that your data is up‑to‑date.

14.1.2                    You have the right to request access to any of your personal data that the Company may hold, and to request correction of any inaccurate data relating to you.  You furthermore have the right to request deletion of any irrelevant data we hold about you.  Please send an email to privacy@tnsi.com.

14.1.3                    To correct/update certain information (such as your address or bank details), you will need to contact local Human Resources at HR-EU@tnsi.com

14.2             Data portability

• Where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to the Company in a structured, commonly used and machine‑readable format, and also to require us to transmit it to another controller where this is technically feasible.

14.3             Right to restriction of processing:

• You have the right to restrict our processing of your personal data where:

14.3.1                    you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;

14.3.2                    where the processing is unlawful but you do not want us to erase the data;

14.3.3                    where we no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or

14.3.4                    where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether the Company has compelling legitimate grounds to continue processing.

• Where personal data is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.

14.4             Right to withdraw consent

• Where we have relied on your consent to process particular information and you have provided us with your consent to process data, you have the right to withdraw such consent at any time. You can do this by (i) in some cases deleting the relevant data from the relevant HR system (although note that in this case it may remain in back‑ups and linked systems until it is deleted in accordance with our data retention policy) or (ii) contacting your local Human Resources contact. It will only however be rarely that we rely on your consent to process personal data for your employment or engagement.

14.5             Right to object to processing justified on legitimate interest grounds

• Where we are relying upon legitimate interest to process data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

14.6             Right to complain

• You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law.

14.7             For further information regarding your rights, or to exercise any of your rights, please contact your Data Protection Officer by email at privacy@tnsi.comor your local Human Resources at HR-EU@tnsi.com

TNS Job Applicant Privacy Policy – Rest of World

Updated 08 November 2021

DEFINITIONS

In this document:

• “Personal Data” means information which identifies or is reasonably capable of being associated with you or your household (or, as applicable, your employer).
• “Job Applicant Privacy Policy” means the current version of this TNS Job Applicant Privacy Policy.
• “We” or “TNS” means Transaction Network Services, Inc., a USA-based corporation registered in Delaware, USA under Delaware Registration No. 3053051. Its principal office is located at Suite 100, 10740 Parkridge Blvd., Reston, Virginia, 20191 USA. TNS has offices in various regions of the world. Please check our websites for more information on our office locations.
• “You” means the person who is applying for a job on our websites.

PRIVACY COMMITMENT

We are committed to respecting your personal privacy, to processing your Personal Data in accordance with your consent, and to protecting any Personal Data that we have collected from you. This Job Applicant Privacy Policy is intended to describe processes for collecting, distributing, and protecting Personal Data, as well as your rights with regards to your Personal Data, specifically in connection with your application for a job through our websites. On our websites, you will be required to indicate that you have read and agree with this Job Applicant Privacy Policy before you will be allowed to apply for a job with us.

If you are a resident of Europe, the Asia-Pacific Region, or the USA, please see our websites for the Job Applicant Privacy Policy specific to your region. This Privacy Policy is intended to apply to those persons who are residents of other parts of the world.

TYPES OF PERSONAL DATA COLLECTED

In connection with your application for a job with us, Personal Data collected by us includes information that you voluntarily submit to us, and may include the following:

• Biographical Information: This includes information you provide to us about yourself, including your name, alias(es), former name(s), gender, date of birth, email address, mobile telephone number, home telephone number, address(es), protected classification(s), language proficiencies, and other information required to determine your eligibility and suitability for a job with us, as well as information about you provided to us by your current or former employers, educational institutions, and co-workers.
• Educational Information: This includes information you provide about educational history, such as the names, places, and dates of attendance and graduation of your schools, trade schools, colleges, and universities, as well as the certificates, diplomas, and degrees awarded, as well as information provided to us by your current or former educational institutions.
• Professional Information: This includes information you provide about your employment history, such as the names, places, and dates of former or current employers, the positions you held, professional qualifications (such as licenses, permits, certifications, and memberships relevant to your work history), as well as information provided to us by your current or former employers and co-workers.
• Job Preference Information: This includes information you provide about the geographical locations, positions, and compensation you seek, as well as your willingness to relocate.
• Interview Information: This includes information you provide to us (whether in person, over the phone, in a virtual meeting, on paper, or otherwise) in the process of our interviewing you for a position with us.
• Other Information: This may include any additional information which you voluntarily provide to us, or make available to us through a third party, in the process of your application for a job with us.

COLLECTION OF PERSONAL DATA

Providing Personal Data to us in connection with your application for a job with us is voluntary. However, if you do not provide us with certain information, or do not provide sufficiently detailed information, we may be unable to consider you for a job with us.

To the extent you voluntarily provide us with your Personal Data in connection with your application for a job with us, or make such Personal Data available to us through a third party, we may collect such Personal Data in the following ways:

• Personal Data You Provide: You may give us your Personal Data (as described above) when you contact us to inquire about available jobs; when you apply for a job with us (whether on our websites, via mail, via email, or otherwise); and/or when you interview with us.
• Personal Data Received from Third Parties: We may receive information about you from third parties, including current or former employers, current or former educational institutions, and current or former co-workers.

USE AND SHARING OF PERSONAL DATA

We may use your Personal Data in several ways, including the following:

• Screening, Recruiting, and Hiring Applicants: We may use your Personal Data to evaluate your eligibility and suitability for one or more positions with us; to schedule and conduct interviews with you; to communicate with you regarding your job application(s); to satisfy our legal obligations (including, for example, our obligations under Equal Opportunity Employment laws); to evaluate and improve our recruiting process; and for routine business purposes. – Sale of Personal Data: TNS does not sell any Personal Data collected in the job application process.

RETENTION OF PERSONAL DATA

At the time we collect your Personal Data in connection with your application for a job with us, we may store such Personal Data for the purposes of evaluating your eligibility and suitability for one or more positions with us. In addition, after the job application process, we may continue to store such Personal Data for the purposes of evaluating your eligibility and suitability for future positions with us. We may also retain certain information obtained from your Personal Data where such information has been aggregated, de-identified, anonymized, or pseudonymized such that it is no longer capable of identifying you, for the purposes of evaluating and improving our recruiting process.

PROTECTION OF PERSONAL DATA

We take precautions to protect the Personal Data we collect and store. All of our employees, as well as all of our service providers who have access to Personal Data, are obligated to protect it and keep it confidential. However, no system or electronic data transmission is completely secure. If you give us your Personal Data, you do so at your own risk. We expect that you will use appropriate security measures to protect your Personal Data.

CONTACT INFORMATION REGARDING PRIVACY

• Contacting Us: You may contact us at any time if you have any questions about this Job Applicant Privacy Policy, to exercise your rights regarding your Personal Data, to file a complaint regarding how we process your Personal Data, or for any privacy-related queries. Please direct all queries and questions regarding privacy to our Data Protection Officer at the following email address: privacy@tnsi.com
• Contacting a Privacy Regulator: If you are not satisfied with our response, you can contact the relevant privacy regulator or agency in your region.

JOB APPLICANT PRIVACY POLICY UPDATES

This Job Applicant Privacy Policy is periodically reviewed and updated. The date of the last update to this Job Applicant Privacy Policy appears at the top of this document. We reserve the right to modify this policy at any time without prior notice.