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 * PRIVACY NOTICE
 * 1. PURPOSE OF THIS PRIVACY NOTICE
 * 2. SCOPE OF THIS PRIVACY NOTICE
 * 3. CHANGES TO THIS NOTICE
 * 4. ABOUT US
 * 5. HOW TO CONTACT US
 * 6. TYPES OF PERSONAL INFORMATION WE COLLECT/PROCESS
 * 7. HOW WE COLLECT PERSONAL INFORMATION
 * 8. WHO WE COLLECT PERSONAL INFORMATION ABOUT
 * 9. HOW WE USE PERSONAL INFORMATION
 * 10. IF YOU FAIL TO PROVIDE YOUR PERSONAL INFORMATION
 * 11. SHARING YOUR PERSONAL INFORMATION
 * 12. ONWARD TRANSFERS
 * 13. OBTAINING YOUR CONSENT
 * 14. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
 * 15. ACCESS
 * 16. OPT OUT AND UNWANTED COMMUNICATIONS
 * 17. ENFORCEMENT RIGHTS AND MECHANISMS
 * 18. THIRD PARTY LINKS AND SERVICES
 * 19. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
 * 20. PERSONAL INFORMATION OF MINORS
 * 21. COUNTRY SPECIFIC PROVISIONS

PRIVACY NOTICE
 * PRIVACY NOTICE
 * 1. PURPOSE OF THIS PRIVACY NOTICE
 * 2. SCOPE OF THIS PRIVACY NOTICE
 * 3. CHANGES TO THIS NOTICE
 * 4. ABOUT US
 * 5. HOW TO CONTACT US
 * 6. TYPES OF PERSONAL INFORMATION WE COLLECT/PROCESS
 * 7. HOW WE COLLECT PERSONAL INFORMATION
 * 8. WHO WE COLLECT PERSONAL INFORMATION ABOUT
 * 9. HOW WE USE PERSONAL INFORMATION
 * 10. IF YOU FAIL TO PROVIDE YOUR PERSONAL INFORMATION
 * 11. SHARING YOUR PERSONAL INFORMATION
 * 12. ONWARD TRANSFERS
 * 13. OBTAINING YOUR CONSENT
 * 14. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
 * 15. ACCESS
 * 16. OPT OUT AND UNWANTED COMMUNICATIONS
 * 17. ENFORCEMENT RIGHTS AND MECHANISMS
 * 18. THIRD PARTY LINKS AND SERVICES
 * 19. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
 * 20. PERSONAL INFORMATION OF MINORS
 * 21. COUNTRY SPECIFIC PROVISIONS


TA DIGITAL

Privacy Notice

Last Updated 14th April 2023


1. PURPOSE OF THIS PRIVACY NOTICE

This Privacy Notice (“Privacy Notice”) sets out how TA Digital branded
companies (herein referred to as “TA Digital”, “we”, “us” or “our”) processes
your personal information in connection with our business, including the
provision of our website (“Site”) and the services we offer (“Services”).

Additionally, this Privacy Notice explains our approach to any personal
information that we might collect from you (i) when you use our Site or Services
(ii) during any other interactions with us, or (iii) which we might otherwise
process when providing Services to our clients (including the personal
information we collect, why we collected it and your rights in respect of our
processing of your personal information).

This Privacy Notice is intended to assist you in making informed decisions when
using the Site and our Services. Please take a moment to read and understand
this Privacy Notice. It is intended to be read in conjunction with our Cookie
Notice.

If you are a California consumer and would like information about our online and
offline privacy practices and your privacy rights, please see the section of
this Privacy Policy called “California Consumer Privacy Statement” by clicking
here.

Please note that a separate notice applies to our processing of personal
information in the European Union and the United Kingdom. To view our EU/UK
Privacy Notice please click here.


2. SCOPE OF THIS PRIVACY NOTICE

This Privacy Notice only applies to the use of your personal information
obtained by us, whether from you directly or from a third party. It does not
apply to personal information collected by third parties during your
communications with those third parties or your use of their products or
services (for example, where you follow links on our Site to third party
websites over which we have no control).

Further, this Privacy Notice is not intended to cover the processing of
workplace personal information.  Accordingly, if you are engaged as a worker for
us, please see our Workplace Privacy Notice which sets out further information
about how we may process your personal information in connection with your
employment and/or engagement.


3. CHANGES TO THIS NOTICE

We will update this Privacy Notice from time to time to reflect any changes or
proposed changes to our use of your personal information, or to comply with
changes in applicable law or regulatory requirements. We may notify you by email
of any significant changes to this Privacy Notice, but we encourage you to
review this Privacy Notice periodically to keep up to date on how we use your
personal information. If we update this Privacy Notice, we will update the 'Last
Updated' date at the top of the page.


4. ABOUT US

The Site and Services are made available by TA Digital and its operating
companies TA Digital Canada, TA Digital India and TA Digital USA, collectively
referred to as "TA Digital".

TA Digital Canada is a Canadian corporation with the registered company name of
TechAspect Digital Canada Inc. with its registered office at 33 Bloor St W #17f,
Toronto, ON M4W 1A6, Canada.

TA Digital India is an Indian corporation with the registered company name of
TechAspect Solutions Private Ltd, with its registered office at 8th Floor, My
Home Twitza, Plot No. 30/A, Survey No. 83/1, TSIIC Hyderabad, Knowledge City Rd,
Hyderabad, 500081, India.

TA Digital USA is USA corporation with the registered company name of TechAspect
Solutions LLC, with its registered office at 720 California Street, San
Francisco, CA USA 94108.


5. HOW TO CONTACT US

If you have any questions about this Privacy Notice or want to exercise your
rights as a data subject set out in this Privacy Notice, you can contact us
using the following methods:

Email 

Send us an email at: privacy@tadigital.com

Post

Write to us at: 

TA Digital
Attn: Privacy Office
720 California Street
San Francisco, CA 94108
USA

Telephone

 +1 510-962-3200


6. TYPES OF PERSONAL INFORMATION WE COLLECT/PROCESS

When we talk about personal information, we mean any information which relates
to an identified or identifiable living individual. Individuals might be
identified by reference to a name, an identification number, location data, an
online identifier (such as an IP address) or to other factors that are specific
to them, such as their physical appearance. Categories of personal information
we may collect and process about you include:

Identity Data

First name; last name.

Contact Data 

Delivery address; billing address; email address; telephone number; social media
handle. 

Applicant Data

Date of birth; gender; country; nationality; resumes, work experience; dietary
requirements any other personal information that you may provide in advance
of/during your supply of services to us.

Image Data

Photos; video recordings.

Financial Data

Bank account details; partial payment card details.

Transaction Data

Details about payments made between you and us; details of services purchased
from us.

Profile Data

Interests and preferences; contact/marketing preferences; feedback and survey
responses.

Behavioral Data

Data relating to your browsing activity, obtained through the use of cookies,
pixel tags and other similar technologies; information about when your current
or previous sessions started; details about any services you viewed or purchased
through the Site.

Technical Data

IP address; browser type and operating system; geolocation, to ensure we’re
showing you the correct notices and information; any other unique numbers
assigned to a device.

Publicly Available Data

Information about articles (or similar) that you may have published; information
about your interests or affiliations or publicly stated positions on political
matter, corporate matters and similar.

For more information about the personal information we collect please refer to
section 'HOW WE USE PERSONAL INFORMATION' below.


7. HOW WE COLLECT PERSONAL INFORMATION

We may collect and receive your personal information using different methods:

Personal information you provide to us 

You may give us your personal information directly, for example, when you obtain
services via our Site, contact us with enquiries, complete forms on our Site,
subscribe to receive our marketing communications or provide feedback to us.

Personal information we collect using cookies and other similar technologies

When you access and use our Site, we may collect certain Behavioral Data and
Technical Data. We collect this personal information by using cookies and other
similar technologies (see the 'Website insight and analysis' section below).

Personal information received from third parties

We may receive personal information about you from third parties. Such third
parties may include analytics providers, data brokers, third party directories
and third parties that provide technical services to us so that we can provide
our Site and our Services.

Publicly available personal information 

From time to time, we may collect personal information about you (Identity Data,
Contact Data, or Publicly Available Data) that is contained in publicly
available sources (including open source data sets or media reports) or that you
or a third party may otherwise make publicly available (for example through
speeches at events or publishing articles or other news stories or posts on
social media platforms).


8. WHO WE COLLECT PERSONAL INFORMATION ABOUT

We collect and process personal information from the following people:

Site visitors

We will collect and process your personal information in connection with your
interaction with us and our Site.

People who contact us with enquiries

If you contact us with an enquiry through our Site, submit a complaint or
provide any feedback to us in our surveys and feedback forms, we will collect
and process your personal information in connection with your interaction with
us and our Site.

Client personnel

We may collect and process your personal information in connection with the
supply of services to you and/or your organization.

Talent

If you supply services and/or content to us and/or work with us to provide
services to our client (including featuring in content we produce), we may
collect or process your personal information, such as your Identity Data,
Contact Data, Financial Data, and Resumes in connection with such supply of
services and/or content to us and our clients.

Partner/supplier personnel 

If you (or your organization) supply products or services to us or otherwise
partner with us, we may collect and process your personal information in
connection with our receipt of those products and services and/or partnership.
This may include personal information included in any email or telephone
communications or recorded on any document relating to an order for the products
or services, such as your Contact Data.

Visitors to our offices or other locations

If you attend one of our physical offices or other locations, we may process
personal information that you volunteer in connection with your visit and any
enquiries you make. For example, you may volunteer personal information when
signing in as a guest, or when you register for and access our guest Wi-Fi
network at our premises. CCTV footage may also be collected for security
purposes.

Event attendees

If you attend one of our events, we will process personal information about you
in connection with your attendance at the event. For example, we may ask you to
complete a registration or feedback form, or other documents relating to the
event.

Job applicants

If you apply for a job with us, whether through the Site or otherwise, we will
collect and process your personal information in connection with your
application.

Members of the public 

We may process your personal information in connection with the provision of the
Services to our clients.


9. HOW WE USE PERSONAL INFORMATION

A: OPERATION OF SITE, PROVISION OF SERVICES AND MARKETING

I. Operation of the Site 

If you browse our Site

When you browse our Site, we may collect and process Behavioral Data and
Technical Data to help us understand how you are using and navigating our Site.
 We do this so that we can better understand which parts of our Site are more or
less popular and improve the structure and navigation of our Site. 

Website insight and analysis

We and our third-party partners might use cookies, web beacons, pixel tags and
other similar technologies (which we generically refer to as “Cookies”) to
collect data from the devices that you use to access our Site.  The data that is
collected could include Behavioral Data and Technical Data, and certain Profile
Data.  Please see our Cookie Policy for further information, including details
of our third-party partners.

We and our third-party partners use this data to analyze how you use our
Site and our Services and the effectiveness of our Site and Services, including:

 * to analyze how you use, and the effectiveness of, our Site and Services;
 * to count users who have visited our Site and collect other types of
   information, including insights about visitor browsing habits, which helps us
   to improve our Site and Services;
 * to measure the effectiveness of our content;
 * to learn what parts of our Site are most attractive to our users, which parts
   of our Site are the most interesting and what kind of features and
   functionalities our visitors like to see; 
 * to help us understand the type of marketing content that is most likely to
   appeal to our visitors and customers.

If you use the interactive features on our Site

We will collect and use personal information about you when you use certain
features on our Site. For example, depending on the nature of your enquiry, we
may process your Identity Data, Contact Data, Registration Data, Profile Data
and certain Behavioural Data and Technical Data when you use the Enquiry Form or
Chat function to get in touch with us or other account holders, or so that you
can be searched for by other account holders.

If you request content from our Site

Our Site features a “Content Request” function, which allows account holders and
third parties to request access to and/or use of content, including photographs,
quotes, testimonials, that has been published on our Site and/or which we
otherwise hold.

If you request content from us, we will ask you to complete the request form,
providing your Identity Data, Contact Data, and any other information relevant
to your request. We will process this information in order to process and
respond to your request.

If you link to social media sites and interact with our social media pages

If you click on one of the social media links on our Site or otherwise interact
with our social media pages such as on Facebook or Instagram (including
interacting with any ‘like’ or similar embedded features on our Site or social
media accounts), we and the relevant social media platform may receive
information relating to such interaction and may share your personal information
in connection with this purpose, such as certain Behavioural Data and Technical
Data. For more information about how we use this personal information, please
see the 'Website insight and analysis' section below.

The relevant social media platform may also be a controller in respect of the
personal information that is collected via your use of our social media pages
and may use that personal information for additional purposes. For details of
how the relevant social media platform uses your personal information, please
see the privacy notice of the relevant social media platform.




II. Provision of our Services 

Provision of client facing services

We may, acting on our own behalf and on behalf of our clients, collect personal
information (including the types of personal information we set out in Section 6
in the 'Types of personal information we collect/process' about you in
connection with the provision of our Services.

Social media

We may collect or process individuals’ personal information (including Contact
Data, Identity Data and some Profile and Publicly Available Data) who engage
with us through our social media channels (including by visiting our social
media pages or otherwise communicating with us via social media).  We may also
operate our client’s social media pages, accounts or channels acting on their
behalf.




III. Marketing and Media Enquiries

Marketing

We may use your Identity Data, Contact Data and Profile Data to send you (or the
organization you represent) marketing communications by email or via phone.  Our
marketing may include press releases and information about us. 

Media and informational inquiries

We may collect personal information (including Identity Data, Contact Data and
Publicly Available Data) about journalists, client contacts or industry contacts
for interviews requests, for media questions, or requests for information about
TA Digital.  We may also provide individuals with the opportunity to sign up for
newsletters or to receive copies of blogs and other information that we make
available.  Where an individual signs up to receive such information, Contact
Data may be requested in each case, together with details of other personal
information that is relevant to these inquiries.  This information is used in
order to enable us to respond to individual requests or media requests. 

Events

From time to time, we may organise and host road shows and other industry events
to promote our services or on behalf of clients. For this purpose we may process
data including Identity Data and Contact Data (including email address, postal
address and telephone number) to communicate with them about such events where
they have specifically requested information about such events or where we have
another lawful basis for sending that information to them.

If you attend one of our events, we may use your personal information to record
your attendance at the event and for related record-keeping purposes and, if
relevant, we may collect and process any dietary or other requirements you may
have. You may also feature in photographs taken at our events and such
photographs may appear in publications we send to our clients and/or publish on
our Site, in print or other media.




B: BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL 

Receipt of services

If we have engaged an organization to provide us or our client with services
(for example, IT support or financial advice), we will collect and process your
personal information (including Contact and Identity Data) if you are a contact
within the relevant organization in order to manage our relationship or our
clients with the organization, to receive services from the organization and,
where relevant, to provide our services to others including our clients.

Recruitment

If individuals apply for a job with us or otherwise express an interest in
working for us, we will collect contact details and CV or resume information
from the individual.  We use such personal information for the following
purposes: a) to assess the individual’s suitability for any position for which
they applied (or future positions for which we think the individual may be
suitable) including employment or freelancer positions, summer placements or
internships and also any business support or services role whether such
application has been received by us online, via email or by hard copy or in
person application; b) to take any steps necessary to enter into any contract of
employment (or otherwise) with the individual; c) to comply with any regulatory
or legal obligations in relation to any such application; and d) to review our
equal opportunity profile in accordance with applicable legislation. We do not
discriminate on the grounds of gender, race, ethnic origin, age, religion,
sexual orientation, disability or any other basis covered by local legislation. 

Visiting our premises, studios or production sites

If an individual visits any of our premises, studios and/or production sites we
may collect personal information including Identity or Contact Data as part of
our sign in process.  We may also capture their image on our surveillance camera
or CCTV. 

If an individual registers as a guest user for free Wi-Fi access at any of our
premises, we may collect personal information including Identity and Contact
Data as part of the registration process.  We may also process Behavioral and
Technical Data in connection with any use of this free Wi-Fi service for
monitoring and record-keeping purposes, including to identify the source of
service requests, optimize and maintain performance of the Wi-Fi service, and
investigate and prevent system abuse. 

Business administration, finance, and legal compliance

We may use an individual’s personal information (including Identity Data,
Contact Data, Financial Data, Transaction Data, Publicly Available Data) for the
following business administration and legal compliance purposes:

 * to facilitate the operation or effective management of our group of
   businesses;
 * for financial, accounting and tax purposes;
 * to comply with our legal obligations;
 * to enforce or protect our legal rights;
 * to deal with complaints;
 * to protect the rights of third parties (including where health or security of
   an individual is endangered (e.g. a fire); and
 * in connection with a business transition or sale such as a merger,
   re-organization, acquisition by another company, or sale of all or a portion
   of our assets.


10. IF YOU FAIL TO PROVIDE YOUR PERSONAL INFORMATION

Where we are required by law to collect your personal information, or we need to
collect your personal information under the terms of a contract we have with
you, and you fail to provide that personal information when we request it, we
may not be able to perform the contract we have or are trying to enter into with
you. This may apply where you do not provide the personal information that we
need in order to provide the Services you have requested from us or to process
an application for employment with us. In this case, we may have to cancel your
application or the provision of the relevant Services to you, in which case we
will notify you.


11. SHARING YOUR PERSONAL INFORMATION

We only share personal information with others when we are legally permitted to
do so. When we share personal information with others, we put contractual
arrangements and security mechanisms in place to protect the personal
information shared and to comply with our data protection, confidentiality and
security standards and obligations.

We may share data (subject to the above) with our partner agencies and other
Omnicom Group companies. For more information about the Omnicom Group, please
see here: Advertising and Marketing Agencies | Omnicom Group 

Further (again subject to the above) we may share your personal information with
third parties as set out in the table below. This list is non-exhaustive and
there may be circumstances where we need to share personal information with
other third parties.

Our ClientsWe may share personal information with our clients for the purposes
of providing them with Services. 
Our specialist suppliers/partners
We use various specialist suppliers including external subject matter experts
and/or partners in order to provide our services including, communications,
promotions and events. 
Third-party IT suppliers 
We may share personal information with third parties who support us in providing
our Site and help provide, run, and manage our internal IT systems. Such third
parties may also include, for example, providers of information technology,
cloud-based software-as-a-service providers, identity management, website
design, hosting and management, data analysis, data back-up, security, and
storage services. The servers powering and facilitating that cloud
infrastructure are located in secure data centers around the world, and personal
information may be stored in any one of them. We may also share your personal
information with third-party service providers to assist us with insight
analytics. These providers are described in our Cookie Notice.
Payment providers and banks
We may share personal information with third parties who assist us with our
invoicing and/or making/receiving payments.
Third-party post/email marketing and CRM specialists
We may share personal information with specialist suppliers who assist us in
managing our marketing database and sending out email marketing communications.
Recruitment agencies and related organizations
We may share personal information with external recruiters, third-party
providers that undertake background checks on our behalf and other entities
within our group of companies for recruitment purposes
Auditors, lawyers, accountants and other professional advisers
We may share personal information with professional services firms who advise
and assist us in relation to the lawful and effective management of our
organisation and in relation to any disputes we may become involved in.
Law enforcement or other government and regulatory agencies and bodies
We may share personal information with law enforcement or other government and
regulatory agencies or other third parties as required by, and in accordance
with, applicable law or regulation.
Other third parties
Occasionally, we may receive requests from third parties with authority to
obtain disclosure of personal information, such as to check that we are
complying with applicable law and regulation, to investigate an alleged crime,
or to establish, exercise or defend legal rights. We will only fulfil requests
for personal information where we are permitted to do so in accordance with
applicable law or regulation.






12. ONWARD TRANSFERS

As we are a group of companies based in Canada, India and the United States, you
acknowledge and agree that any data that is provided directly to us may be
stored in those countries. We may also transmit your personal information to
other third parties outside of those countries (as listed above in 'SHARING YOUR
PERSONAL INFORMATION' and more specifically to the offices of other global
Omnicom Group entities, networks or partners agencies.


13. OBTAINING YOUR CONSENT

Where our use of your personal information requires your consent, you can
provide such consent:

 * at the time that we collect your personal information following the
   instructions provided; or
 * by informing us by e-mail, post or phone using the contact details set out in
   this Privacy Notice.

Please note that if you specifically consent to additional uses of your personal
information, we may use your personal information in a manner consistent with
that consent.


14. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure
and we have implemented information security policies, rules and technical
measures to protect the personal information under our control from unauthorized
access, improper use or disclosure, unauthorized modification and unlawful
destruction or accidental loss. In addition, all our employees and data
processors (i.e. those who process your personal information on our behalf) are
obliged to respect the confidentiality of the personal information of all users
of our Site and those who purchase our Services.


15. ACCESS

To the extent required by applicable law, we will provide you with reasonable
access to the personal information maintained about you and a reasonable
opportunity to correct, amend or delete the information where it is inaccurate
or has been processed erroneously, as appropriate. We may limit or deny access
to personal information where permitted by law (such as where the burden or
expense of providing access would be disproportionate or where the rights of
third parties would be violated).

You may exercise these rights verbally or in writing by using our contact
information provided in the section entitled 'HOW TO CONTACT US' above. We will
endeavor to promptly respond to your requests and will respect time frames set
by local legislation where applicable.

Please note that in order for you to assert these rights we may need to verify
your identity to confirm your right to access your personal information. This is
a security measure to ensure that personal information is not disclosed to any
person who has no right to receive it. In order to verify your identity, we may
need to gather more personal information from you than we currently have.


16. OPT OUT AND UNWANTED COMMUNICATIONS

To opt-out of any future promotional or marketing communications or any other
commercial communications from us, you should send a request to us at the
contact information in the section entitled 'HOW TO CONTACT US' above. 


17. ENFORCEMENT RIGHTS AND MECHANISMS

We will ensure that this Policy is observed and duly implemented. If at any time
you believe that your personal information has been processed in violation of
this Policy, or if you have any inquiries or complaints about the use or
limitation of use of your personal information, you may send a request to us at
the contact information in the section entitled 'HOW TO CONTACT US' above.


18. THIRD PARTY LINKS AND SERVICES

This Site contains links to third party websites and services. Please remember
that when you use a link to go from our Site to another website or you request a
service from a third party, this Privacy Notice no longer applies to these
third-party websites and third-party service providers unless we are acting as
joint controllers in respect of your personal information with such third party.

Your browsing and interaction on any other websites, or your dealings with any
other third-party service provider, is subject to that website’s or third-party
service provider’s own rules and policies. We do not monitor, control, or
endorse the privacy practices of any third parties.

This Site may integrate with social networking services. You understand that we
do not control such services and are not liable for the manner in which they
operate. While we may provide you with the ability to use such services in
connection with our Site, we are doing so merely as an accommodation and, like
you, are relying upon those third-party services to operate properly and fairly.


19. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We retain personal information only for as long as is necessary for the purposes
described in this Privacy Notice, after which it is deleted from our systems.

If any personal information is only useful for a short period (e.g. for a
specific event or marketing campaign or in relation to recruitment), we will
delete it at the end of that period. Please note that if you are an unsuccessful
candidate, we may keep your information for a short period.

If you have opted out of receiving marketing communications from us, we will
need to retain certain personal information on a suppression list so that we
know not to send you further marketing communications in the future.


20. PERSONAL INFORMATION OF MINORS

Our Site is not intended for use by, or targeted at, minors (individuals under
the age of 18) and we do not knowingly collect personal information of minors.
However, due to the nature of our organization and the Services we provide, we
may from time-to-time collect and process personal information relating to
minors. If we do collect personal information of minors, we will comply with all
applicable laws and regulations relating to the processing of personal
information of minors.


21. COUNTRY SPECIFIC PROVISIONS

UNITED STATES

California Consumer Privacy Statement

Last Updated:  1st March 2023

This California Consumer Privacy Statement (“Statement”) supplements the TA
Digital Privacy Notice. It applies solely to California consumers and addresses
personal information we collect online and offline. This Statement does not
apply to TA Digital personnel. Sections 2-5 of this Statement do not apply to
job applicants.

This Statement uses certain terms that have the meaning given to them in the
California Consumer Privacy Act of 2018 and its implementing regulations (the
“CCPA”).

 1. Notice of Collection and Use of Personal Information 

We may collect (and may have collected during the 12-month period prior to the
effective date of this Statement) the following categories of personal
information about you: 

 * 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; customer number, unique
   pseudonym, or user alias; telephone number and other forms of persistent or
   probabilistic identifiers), online identifier, internet protocol address,
   email address, account name, Social Security number, driver’s license number,
   passport number, and other similar identifiers
 * Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical
   characteristics or description, state identification card number, insurance
   policy number, education, bank account number, credit card number, debit card
   number, and other financial information, medical information, and health
   insurance information
 * Protected Classifications: characteristics of protected classifications under
   California or federal law, such as race, color, national origin, religion,
   age, sex, gender, gender identity, gender expression, sexual orientation,
   marital status, medical condition, ancestry, genetic information, disability,
   citizenship status, and military 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 
 * Sensory Information: audio, electronic, visual, and similar information 
 * Employment Information: professional or employment-related information 
 * Education Information: education information that is not publicly available
   personally identifiable information as defined in the Family Educational
   Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
 * Inferences: inferences drawn from any of the information identified above to
   create a profile about you reflecting your preferences, characteristics,
   psychological trends, predispositions, behavior, attitudes, intelligence,
   abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective
date of this Statement) your personal information for the purposes described in
our online Privacy Notice and for the following business purposes specified in
the CCPA:

 * Performing services, including maintaining or servicing accounts, providing
   customer service, processing or fulfilling orders and transactions, verifying
   customer information, processing payments, providing advertising or marketing
   services, providing analytics services, or providing similar services
 * Auditing related to a current interaction with you and concurrent
   transactions, including, but not limited to, counting ad impressions to
   unique visitors, verifying positioning and quality of ad impressions, and
   auditing compliance
 * Short-term, transient use, including, but not limited to, the contextual
   customization of ads shown as part of the same interaction
 * Detecting security incidents, protecting against malicious, deceptive,
   fraudulent, or illegal activity, and prosecuting those responsible for that
   activity
 * Debugging to identify and repair errors that impair existing intended
   functionality
 * Undertaking internal research for technological development and demonstration
 * 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.
 * Managing career opportunities with TA Digital.
   
   

 2. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may
have obtained personal information about you from the following categories of
sources:

 *  Directly from you, such as when you contact us with a question or comment
 *  From your devices, such as when you visit our Site
 *  Vendors who provide services on our behalf
 *  Social networks
 *  Government entities
 *  Data brokers
   
   

 3. Sale of Personal Information

We do not and will not sell your personal information.



 4. Sharing of Personal Information

During the 12-month period prior to the effective date of this Statement, we may
have shared your personal information with certain categories of third parties,
as described below.

We may have disclosed the following categories of personal information about you
for a business purpose to the following categories of third parties:

Category of Personal Information

Category of Third Party

Identifiers

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

Additional

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

Protected Classifications

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

Commercial

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

Online Activity

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

Employment Information

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

Education Information

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

Inferences

Our affiliates and subsidiaries; Vendors who provide services on our behalf;
Professional services organizations, such as auditors and law firms; Our
business partners; Advertising networks; Internet service providers; Data
analytics providers; Operating systems and platforms; Social networks

In addition to the categories of third parties identified above, during the
12-month period prior to the effective date of this Statement, we may have
shared personal information about you with the following additional categories
of third parties: Government entities.



 5. California Consumer Privacy Rights 

You have certain choices regarding our use and disclosure of your personal
information, 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 about you during the past 12 months.  

Deletion: You have the right to request that we delete certain personal
information we have collected from you.

How to Submit a Request: To submit an access or deletion request (or to submit a
request as an authorized agent on behalf of a consumer), email us at the address
provided in the section entitled 'HOW TO CONTACT US' above.  For questions or
concerns about our privacy policies and practices, please contact us as
described in the section entitled 'HOW TO CONTACT US' above.

Verifying Requests: To help protect your privacy and maintain security, we will
take steps to verify your identity before granting you access to your personal
information or complying with your request.  If you request access to or
deletion of your personal information, we may require you to provide any of the
following information:  your email address, the name of the TA
Digital representative with whom you typically interact, and the date of your
last interaction with a TA Digital representative.  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.   

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.




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