Effective: 17 October 2019

Introduction and Scope

Global Tax Network US, LLC and our controlled U.S. subsidiaries Global Tax Network Atlantic, LLC, Global Tax Network Great Lakes, LLC, Global Tax Network Pacific, Global Tax Network South, LLC, Global Tax Network West Central, LLC, and GTN Shared Services, LLC (collectively, “GTN” “we,” “us,” “our”) takes the protection of your personally identifiable information (PII) very seriously. This GTN Website Privacy Policy (the “Policy”) applies to PII processed in connection with GTN’s sales and marketing operations, including where we received PII when you use GTN’s website, available at: https://www.gtn.com. This Policy explains how we collect and use your PII for these purposes.

This Policy does not address processing of PII in the context of our professional services or web applications, such as the My GTN Portal or our payment processing application (collectively, the “Applications and Services”). If you use the Applications and Services, the PII processed therein will be processed according to the GTN Applications and Services Privacy Policy, available here: https://www.gtn.com/privacy-policy.php

Controllership

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, or contact us by email, phone, or through a web form.

How We Use Your Data

GTN Will Use PII to:

  • manage our customer relationships;
  • contact you and to respond to your sales inquiries, and/or other requests or questions;
  • 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 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 to be able to carry out the contract. Without that necessary PII, we will not be able to provide the services to you.

Cookies

A “cookie” is a small file stored on your device that contains information about your computer. We may use cookies for session management, targeted advertising, and web analytics.

The use of cookies is industry standard, so your browser may be set to accept cookies. If you would prefer not to accept cookies, you can alter the configuration of your browser to reject all cookies or some cookies. Note, if you reject certain cookies, you may not be able to access all of the features available on our website.

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; and
  • customer relationship management (CRM) software.

We may also share your contact information, including your name and email address, with cooperating companies in order to send you informational surveys about our services and our industry.

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.

Also, some of these third parties may be located outside of the European Union or the European Economic Area. In some cases, the European Commission may not have determined that the countries’ data protection laws provide a level of protection equivalent to European Union law. We will only transfer your PII to third parties in these countries when there are appropriate safeguards in place. These may include 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.

Data Retention

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.

Children’s Privacy

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.

EU Representative

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.
Klimentská 46
Prague 1, 11002
Czech Republic

VeraSafe Ireland Ltd
Unit 3D
North Point House
North Point Business Park
New Mallow Road
Cork T23AT2P
Ireland

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.

Contact Us

If you have any questions about this Policy or our processing of your PII, please write to us by email at privacy@gtn.com or by postal mail at:

Global Tax Network US, LLC
Attn: COO / Data Privacy & Security Officer
7950 Main Street N, Suite 200
Maple Grove, MN 55369
USA

We will respond to your inquiry within one month or less.

US Regulatory Oversight

GTN is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.