Last Updated: September 18th, 2023
Your privacy is important to TDN2K, LLC (also known as GuestXM) and its affiliates (together, “Company,” “our,” “us,” or “we”). To better protect your privacy, we are providing information explaining our online information practices with regard to information that may be used to identify you (“Personal Information”).
2. NOTIFICATION OF CHANGES
3. THE PERSONAL INFORMATION WE COLLECT
Depending on how you interact with us, you may provide us various types of information.
Your Use of this Website
- We may collect various types of information from users of this Website. For example, knowing how users use our website – tracking their movement through this Website – helps us improve website design and usefulness. As a result, Company’s server collects general data pertaining to users, including the length of time spent on this Website, the pages accessed while visiting the Website and Internet Protocol (IP) addresses.
- Company generally does not, however, collect any Personal Information such as names, home addresses or e-mail addresses from users of this Website. However, a user may submit certain Personal Information (such as name, company name, company title, e-mail address and phone number) to us through the Website to request a demonstration of our services or obtain other information about us or the services we provide, or through electronic communications (e.g., email) with Company personnel.
We may collect Personal Information to provide specific services business partners including without limitation collecting information from customer surveys, through other customer experience mechanisms which solicit feedback from our business partner’s customers or employees and from public sources (e.g., your public social media posts). Information that may be collected in connection with such services may include your name, email address, phone number, and any text or other responses or feedback you may submit.
We may collect Personal Information about you through automated methods such as your internet protocol (as further described in Section 4), referring webpage or application, online activity on other websites, applications or social media.
Connectors to Third Party Systems
As part of our services, we offer features to our clients that enable a connection to third party systems (like Google) permitting us to pull certain of your data (which may include Personal Information) into our application. For example, you may select a feature connecting your company email inboxes (typically those used for support) to our systems through which we are able pull the data from your inbox into our application.
4. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We use the Personal Information we collect to:
- Improve the Website and design;
- To respond to and communicate with potential customers contacting us through the Website;
- To provide information about our services to our customers or business partners on our Website;
- To the extent that you provide us with any Personal Information through or in connection with this Website, we may use such information for Company’s business purposes, but will not disclose any Personal Information about you to anyone, except as permitted or required by law or regulation and to service providers.
- We may use Personal Information to provide our specific services to the business partner. For example, we may collect Personal Information in connection with collecting and analyzing customer feedback and satisfaction level on behalf of a business partner who has entered into an agreement with us.
- We may combine Personal Information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
- Should you elect to use connectors to the third party systems (as described in Section 3 above), we can:
- View the email inbox or a folder, including all messages in that folder;
- Read and respond to emails in that selected folder; and
- Perform sentiment analysis on all the messages in that folder.
- We may also share your Personal Information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business.
You may access any Personal Information we have about you by contacting Support@guestxm.com.
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we make an effort to protect your Personal Information, we cannot guarantee the security of any information or data transmitted to or through our Website; any transmission of information or data by you to or through this Website is at your sole risk.
9. CONTACT US
What information do we collect about you?
We collect limited types of personal information through our website, as well as through other electronic communications (e.g., emails), or information you may provide to us otherwise, as applicable (collectively, the “Website”). The types of personal information we collect about you depends on the nature of your interaction with us. The categories of personal information we have collected from individuals on this Website over the last twelve (12) months include the following:
- Identifiers, such as name, contact details and address (including physical address, email address and Internet Protocol address);
- Other customer records, such as telephone number, email address and personal information provided in connection with obtaining a demonstration of our services;
- Commercial information, such as information about your company;
- Professional or employment-related information; such as your position in your company;
- Internet or other electronic network activity information, such as information regarding your use of our Website (e.g., cookies, browsing history and/or search history), as well as information you provide to us when you correspond with us in relation to inquiries.
- On behalf of business partners, such as information from customer surveys, through other customer experience mechanisms which solicit feedback from our business partner’s customers or employees and from public sources (e.g., your public social media posts).
We do not knowingly collect or solicit personal information from anyone under the age of 18.
How do we obtain your personal information?
In connection with forming and operating our Website, we collect and maintain your nonpublic personal information from the following sources:
- Information from your communications with us in connection with this Website.
- Information captured on our Website, including registration information, information provided through online forms and any information captured via cookies.
- Information captured through customer surveys or other sentiment mechanisms by our business partners.
We may combine personal information that you provide to us with information that we collect from or about you from publicly available sources. This will include information collected in an online or offline context.
How do we use your personal information?
We will use your personal information for one or more of the following business purposes:
- To provide demonstrations of our services to you.
- To perform services for you.
- To perform services for our business partners.
- To improve our Website and the products and services that we offer and notify you about changes to our products and services.
- To communicate with you, including responding to requests for information submitted by you through our Website.
- To keep a record of your relationship with us.
- Ongoing operations, administrative, accounting, reporting, account maintenance and other processes.
- To audit and verify the quality and effectiveness of our services and compliance.
- To detect security incidents and to protect against malicious, deceptive, fraudulent, or illegal activity.
- To generally comply with U.S., state, local and non-U.S. laws, rules and regulations.
Additionally, we may use your personal information to keep you informed of our products and services, if you have provided your consent to us doing so, or where we have an existing relationship with you and we wish to contact you about products and services similar to those which we provide you, in which you may be interested. You may opt-in to certain kinds of marketing, or all forms of marketing at any time, by contacting us and you may unsubscribe to receiving emails by clicking on the “opt-out” or “unsubscribe” link provided in all our marketing emails.
Who do we share your personal information with?
We do not sell any of the personal information we collect about you to third parties.
We do not disclose any nonpublic personal information about you to anyone, except as permitted or required by law or regulation and to affiliates and service providers, including but not limited to administrators, lenders, banks, brokers, dealers, auditors, tax advisors, accountants, law firms, governmental agencies or pursuant to legal process, self-regulatory organizations, consultants and placement agents. If we collect your personal information on behalf of a business partner, we may disclose such information to such business partner in connection with such services. We may also disclose your information to other parties as may be required by law or regulation, or in response to regulatory inquiries.
Within the last twelve (12) months, we have shared each of the categories of personal information collected in connection with this Website with affiliates and service providers as set forth above in
In the section entitled “What information do we collect about you?”.
We may also share your personal information with applicable third parties in the event of a reorganization, merger, sale, acquisition, assignment, bankruptcy proceeding, or other disposition of all or a portion of our business, assets or shares.
How do we keep your personal information secure?
We consider the protection of sensitive information to be a sound business practice, and to that end we employ appropriate organizational, physical, technical and procedural safeguards, which seek to protect your personal information in our possession or under our control to the extent possible from unauthorized access and improper use. We do not sell or share personal data that California defines as “sensitive personal information.”
Your rights under the CCPA
Deletion Rights: You have the right to request that we delete any of your personal information that we retain, subject to certain statutory exceptions, including, but not limited to, our compliance with U.S., state, local and non-U.S. laws, rules and regulations. We will notify you in writing if we cannot comply with a specific request and provide an explanation of the reasons.
Disclosure and Access Rights: You have the right to request that we disclose to you certain information regarding our collection and use of personal information specific to you over the last twelve (12) months. Such information includes:
- the categories of personal information we collected about you;
- the categories of sources from which the personal information is collected;
- our business or commercial purpose for collecting such personal information;
- the categories of third parties with whom we share the personal information;
- the specific pieces of personal information we have collected about you; and
- whether we disclosed your personal information to a third party, and, if so, the categories of personal information that each recipient obtained.
No Discrimination: We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services or suggesting that you will receive, or providing, a different level or quality of service to you.
How to Exercise Your Rights: To exercise any of your rights under the CCPA, or to access this notice in an alternative format, please submit a request on your behalf using any of the methods set forth in the Contact us section below.
For any requests relating to the exercise of your rights under the CCPA, or questions regarding our processing of your personal information, please submit or have your authorized representative submit a request using any of the methods set forth below.
Email the following email address: firstname.lastname@example.org.
Write to the following address: GuestXM, 14785 Preston Road, Ste 290, Dallas, TX 75254, Attention: Customer Support
If you would like to contact us by telephone without incurring telephone charges, please submit your request and telephone number by email at the email address above, and we will call you between 8 a.m. and 5 p.m. Central Time.
We will contact you to confirm receipt of your request under the CCPA and request any additional information necessary to verify your request. We verify requests by matching information provided in connection with your request to information contained in our records. Depending on the sensitivity of the request and the varying levels of risk in responding to such requests (for example, the risk of responding to fraudulent or malicious requests), we may request further information or your investor portal access credentials, if applicable, in order to verify your request. You may designate an authorized agent to make a request under the CCPA on your behalf, provided that you provide a signed agreement verifying such authorized agent’s authority to make requests on your behalf, and we may verify such authorized person’s identity using the procedures above.
Last Updated: September 11th, 2023
We rely on various legal bases under applicable data protection legislation in order to process your personal information (e.g., name, title, address, email, marital status, date of birth, IP address, financial data, username, password, etc.), including our legitimate interests, contractual necessity and as required by law. We use the personal information we collect to operate our business and provide you with the services and products we offer and perform essential business operations. We do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If we require your personal information due to a legal requirement or obligation or in order to perform services for you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data. Failure to provide this information means that we cannot provide our services or products to you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at that time.
Further information about the legal bases under which we process your personal information is included in the section headed “Why we use your personal information.”
HOW WE OBTAIN YOUR PERSONAL INFORMATION
Information you provide to us
We collect your personal information when you decide to interact with us and we only collect the information necessary to carry out our business for the purposes set out below. You can provide us with personal information via online form, email, post, telephone and this website. We also collect information about you through automated technology.
Information provided by third parties or publicly available sources
We also process information in relation to companies that we are evaluating in connection with a potential business arrangement.
WHY WE USE YOUR PERSONAL INFORMATION
To the extent that you provide us with any personal information, through or in connection with this website (i.e., via online form, telephone, email or post), we may use such information for the following purposes:
- To keep a record of your relationship with us – legitimate interest
- To verify your identity – legal requirement
- To provide services to our business partner – legitimate interest
- To conduct due diligence activities in connection with an actual or prospective business arrangement with respect to which we are party to – legitimate interest
- Fraud and abuse prevention – legitimate interest
- Litigation management and conducting internal audits and investigations – legitimate interest
- To administer and protect our business and this website -legitimate interest
- To make suggestions and recommendations to you about goods or services that may be of interest to you – legitimate interest
No automated decision-making, including profiling, is used when processing your personal information.
We may send you direct marketing communications to keep you informed of our products and services in which you might be interested either where we have obtained your prior consent or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt-in to certain kinds of marketing, and all forms of marketing at any time, by emailing email@example.com. You can also click on the “opt-out”/unsubscribe link provided in our marketing emails, if applicable, or by contacting firstname.lastname@example.org.
DISCLOSURE AND TRANSFER OF PERSONAL INFORMATION
Unfortunately, the transmission of information and data via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of any information or data transmitted to or through this website; any transmission of information or data by you to or through this website is at your sole risk.
Your personal information will be shared with and processed by our affiliates and certain service providers as necessary to fulfil the purposes set out in this policy, including employees, administrators, data processors, data hosting providers and persons employed and/or retained by them. We seek assurances that our standards for data security are met by anyone who enters into an agreement providing a service to, or for us, involving personal data. To the extent your personal information is transferred to countries outside of the EEA, such transfers will only be made in accordance with applicable data privacy laws. For further information about the safeguards/derogations used, please contact email@example.com.
We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition, we may disclose your personal information to the new owner of the relevant business and their advisors on the basis of our legitimate interest.
SECURITY AND RETENTION OF PERSONAL INFORMATION
We are committed to protecting the personal information you entrust to us. We adopt robust and appropriate technologies and policies, so the information we have about you is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
This website is only intended for individuals who are at least 18 years of age. We do not knowingly encourage or solicit visitors to this website who are under the age of 18 or knowingly collect personal information from anyone under the age of 18 without parental consent. If we learn we have collected or received personal information from an individual under the age of 18, we will delete that information.
You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact firstname.lastname@example.org.
Access: You have the right to ask for a copy of the personal information that we hold about you free of charge; however, we may charge a “reasonable fee,” if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
Correction: You may notify us of changes to your personal information if it is inaccurate or it needs to be updated.
Deletion: If you think that we should not be holding or processing your personal information any more, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
NOTIFICATION OF CHANGES