Effective: 28 January 2021
Introduction and Scope
In the context of this Policy, GTN acts as a data controller for PII we process about you.
Data We Collect
We may process the following categories of PII about you:
- biographical information such as first and last name;
- contact information such as phone number, email address, and mailing address;
- professional information such as job title and position; and
- any other categories of PII you choose to submit to us by email, phone, or through a web form.
We may receive your PII from you directly, when you visit our website, participate in a GTN Event, or contact us by email, phone, teleconferencing software, or through a web form.
How We Use Your Data
GTN Will Use Your PII to:
- manage our customer relationships;
- contact you and to respond to your sales inquiries, and/or other requests or questions;
- facilitate your participation in a GTN Event;
- help improve our website; and
- enable us to send you our email newsletter.
Basis of Processing
Within the scope of this Policy, GTN processes PII on the basis of the need to perform our contractual obligations, or to take pre-contractual measures at your request. Additionally, GTN may process PII on the basis of the pursuit of our legitimate interests, such as marketing, selling, and providing our services to prospective and current customers. In certain cases, GTN relies on your consent as the basis for processing. In such cases, you may revoke your consent at any time. To do so, please contact GTN using the contact information in the “Contact Us” section of this Policy. Where we receive your PII as part of providing our services to you based on a contract, we require such PII (and in some cases, we will need your consent to process your PII) to be able to carry out the contract. Without that necessary PII, we will not be able to provide the services to you.
Sharing PII with Third Parties
We may use third-party vendors to perform certain services on our behalf. These third-party vendors include those providing:
- hosting services;
- payment processing services or software;
- e-signature software; and
- customer relationship management (CRM) software.
We may share your PII with these third-party vendors solely to enable them to perform the services for us. In providing them with your PII, we require that these third-party vendors maintain at least the same level of data protection that we maintain for your PII. We do not provide your PII to parties unconnected with the services we provide.
We may also share your contact information, including your name and email address, with affiliated cooperating companies in order to send you informational surveys about our services and our industry.
When you participate in a GTN Event, we may, with your permission, share your contact information, including your name and email address, with our business partners and GTN Event sponsors for marketing purposes.
Also, some of these third parties may be located outside of the country that you reside in. In some cases, the authorities in your country may not have determined that the data protection laws in the countries where our third party service providers are located provide a level of protection equivalent to the laws in your country. We will only transfer your PII to third parties in these countries when there are appropriate safeguards in place. For example, if you are resident in the EU and the European Commission has not determined that the countries where our third party service providers are located provide an adequate level of protection for your PII, we will ensure that we have appropriate safeguards in place with the third parties, such as the European-Commission-approved standard contractual data protection clauses.
Other Disclosure of Your PII
We may also disclose your PII:
- to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
- if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or
- to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.
We reserve the right to use, transfer, sell, and share aggregated, anonymous data, which does not include any PII, about the users of our Service as a group for any legal business purpose, such as analyzing usage trends and seeking compatible advertisers, sponsors, clients, and customers.
If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.
PII processed by us in the context of this Policy may be retained indefinitely. However, you may send a request to us to ask to delete your PII, subject to the limitations described in this Policy.
Data Integrity & Security
GTN has implemented and will maintain technical, administrative, and physical measures that are reasonably designed to help protect PII from unauthorized processing such as unauthorized access, disclosure, alteration, or destruction.
How We Respond to Do Not Track Signals
Our website does not have the capability to respond to “Do Not Track” signals received from various web browsers. Please note that we do not allow third parties to collect PII about your online activities while using our website.
Accessing, Deleting & Updating Your PII
If you are a data subject about whom we store PII, you may have a right to request access to, and the opportunity to update, port, correct or delete such PII. Under certain circumstances, you may have a right to restrict or object to the processing of your PII. To submit such requests or raise any other questions, please reach out to us by using the contact information provided in the “Contact Us” section below.
Our services are not designed to collect data from children under the age of 13. We do not knowingly collect PII from anyone under 18. If you believe your child’s PII may be processed in our services, you can contact us using the information in the “Contact Us” section of this Policy to request that we delete the PII.
Changes to this Policy
If we make any material change to this Policy, we will post the revised Policy to this web page and update the “Effective” date above to reflect the date on which the new Policy became effective.
VeraSafe has been appointed as GTN's representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to GTN, only on matters related to the processing of PII. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative
Alternatively, VeraSafe can be contacted as follows:
VeraSafe Czech Republic s.r.o.
Prague 1, 11002
VeraSafe Ireland Ltd
North Point House
North Point Business Park
New Mallow Road
If you are a resident of the European Union, you may have the right to lodge a complaint with a data protection regulator in one or more of the EU member states.
VeraSafe has been appointed as GTN's representative in the United Kingdom for data protection matters, pursuant to Article 27 of the United Kingdom General Data Protection Regulation. If you are located within the United Kingdom, VeraSafe can be contacted in addition to GTN, only on matters related to the processing of your PII. To make such an inquiry, please contact VeraSafe using this contact form: https://verasafe.com/public-resources/contact-data-protection-representative or via telephone at +44 (20) 4532 2003.
Alternatively, VeraSafe can be contacted at:
VeraSafe United Kingdom Ltd.
37 Albert Embankment
London SE1 7TL
If you have any questions about this Policy or our processing of your PII, please write to us by email at email@example.com or by postal mail at:
Global Tax Network US, LLC/GTN Canada Mobility Tax Services, ULC
Attn: COO / Data Privacy & Security Officer
6900 Wedgwood Road N, Suite 400
Maple Grove, MN 55311
We will respond to your inquiry within one month or less.