TCNY Global LLC dba Tech Career USA Coaching (referred to as “we”, “our”, or “us”) offers remote coaching nationwide through Zoom and is located in the State of New York. When we say “you” or “your” we mean any user of our website, www.TechCareerUSA.com, our application or both, any user of our service and any person who has notice of this Privacy Policy (the “Site”).

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Site and tells you about your privacy rights and how the law protects you. We use your Personal Data to provide and improve the Site. By accessing the Site, you agree to be bound by the following privacy policy (the “Privacy Policy”). If you do not agree to this Privacy Policy, you may not access or use the Site.

1.  DEFINITIONS

 For the purposes of this Privacy Policy:

• “Account” means a unique account created for you to access our Site or parts of our service.

• “Affiliate” means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

• “Application” refers to the software program and/or app provided by us.

• “Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many

• “Country” refers to New York, United States

• “Device” means any device that can access the Site such as a computer, a cellphone or a digital

• “Personal Data” is any information that relates to an identified or identifiable individual.

• “Service Provider” means any natural or legal person who processes the data on behalf of the It refers to third-party companies or individuals employed by the Company to facilitate the Site, to provide the service on behalf of the Company, to perform services related to the Site or to assist the Company in analyzing how the Site or services are used.

• “Usage Data” refers to data collected automatically, either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit).

2.  TYPES OF DATA COLLECTED

1. Personal Data

 While using our Site or services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Commercial information including, but not limited to purchase and transaction history information, and travel and vacation information

• Demographic information including, but not limited to age, gender, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment

• Financial information including, but not limited to credit or debit card numbers, and financial account numbers.

• Background information including, but not limited to background and criminal information, such as background checks and criminal convictions

• Inferences including, but not limited to individual preferences and characteristics and inferences drawn therefrom.

• Usage Data

B.  Usage Data

Usage Data is collected automatically when using the Site. Usage Data may include, but is not limited to information such as your Device’s internet protocol address (e.g. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Site by or through a mobile device, we may collect certain information automatically including, but not limited to the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers, your browsing or search activity as well as your interactions with our Site and other diagnostic data. We may also collect information that your browser sends whenever you visit our Site or when you access the Site by or through a mobile device.

3.  COLLECTION OF YOUR PERSONAL DATA

We may obtain and combine Personal Data from different sources, collected online and offline including, but not limited to information from third-party sources across different types of technology and devices.

A.  Provided Directly by You or a Member of Your Household

 When you visit our Site, you may share different types of Personal Data with us when you engage in the activities below:

• Conduct a transaction on our Site or request a service where we collect information (including when required by law).

• Create an account on our Site.

• Request customer service or contact us.

• Post a rating, review, video, comment or other user-generated content on our Site, website or mobile services, or post a review, rating, video, comment or other

user-generated content on one of our social media pages.

• Interact with various types of technologies, applications and features.

• Use features of our Site that enable us, with your consent, to access the camera, microphone, or contacts on your computer or mobile Device to provide you with functionality, such as voice search, scanning bar codes for online search, or importing your mobile contacts. You must give us your permission before we access these features, and you can opt out of providing access to them at any time by adjusting the settings on your Device.

B.  Collected Through Automated Means

We may obtain Personal Data about you such as Device and online identifiers and internet or other network activity information via automated means through your use of technology, such as when you visit our Site, or click on advertisements or links in emails you receive from us.

Also, depending on your Device’s settings, we may collect precise geolocation information. You can control our ability to do this by adjusting the location-sharing settings on your Device at any time. You also may adjust your Device’s Bluetooth settings to disable the sharing of Bluetooth location-related data.

C.  Obtained from External Third-Party Sources

We may obtain Personal Data about you from other sources to help us correct or supplement our records, improve the quality or personalization of our Site or services, increase the appeal and relevance of advertising, and to prevent or detect fraud. We also may obtain Device and browsing information, from third parties for marketing purposes.

D.  Collected from Another Solution or Asset

For example, when you call us, we collect your Personal Data using call recording technology in accordance with applicable law.

4.  TRACKING TECHNOLOGIES AND COOKIES

We use Cookies and similar tracking technologies to track the activity on our Site and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Site. The technologies we use may include:

• Cookies or Browser A cookie is a small file placed on your Device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Site. Unless you have adjusted your browser setting so that it will refuse Cookies, our Site may use Cookies.

• Web Certain sections of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. You can learn more about cookies here: www.allaboutcookies.org.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies Administered by: Us

Purpose: These Cookies are essential to provide you with services available through the Site and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and we only use these Cookies to provide you with those services.

Cookies Policy / Notice Acceptance Cookies

 Type: Persistent Cookies Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Site.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Site.

For more information about the Cookies we use and your choices regarding Cookies, please see our Cookies Policy.

5.  COOKIES POLICY

By accessing the Site, you agree to be bound by the following cookies policy (the “Cookies Policy”). If you do not agree to this Cookies Policy, you may not access or use the Site.

This Cookie Policy explains how and why cookies, web beacons, pixels, clear gifs, and other similar technologies (collectively “Cookies”) may be stored on and accessed from your device when you use or visit the Site. This Cookie Policy should be read together with our Privacy Policy, our Terms of Use, and all other policies of ours found at: www.TechCareerUSA.com.

Cookies do not typically contain any information that personally identifies a user. A cookie is a small text file that can be stored on and accessed from your device when you our Sites, to the extent you agree. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Site. This allows our Site to recognize your device from those of other users of the Site. The information provided below about cookies also applies to these other tracking technologies. You can find more information at www.allaboutcookies.org. For further information on how we use, store and keep your personal data secure, see our Privacy Policy.

A.  How We Use Cookies And The Type Of Cookies We Use

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. We may collect information about you whether you open or click any links on our Site. We use both session and persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies Administered by: Us

Purpose: These Cookies are essential to provide you with services available through the Site and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that you have asked for cannot be provided, and We only use these Cookies to provide you with those services.

Functionality Cookies

Type: Persistent Cookies Administered by: Us

Purpose: These Cookies allow us to remember choices you make when you use the Site, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid you having to re-enter your preferences every time You use the Site.

B.  Your Choices Regarding Cookies

If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Site from placing further Cookies on your device unless and until you adjust your internet browser setting as described below.

If you prefer to avoid the use of Cookies on the Site, first you must disable the use of Cookies in your internet browser and then delete the Cookies saved in your internet browser associated with this Site. You may use this option for preventing the use of Cookies at any time.

If you do not accept Our Cookies, You may experience some inconvenience in your use of the Site and some features may not function properly.

If you would like to delete Cookies or instruct your internet browser to delete or refuse Cookies, please visit the help pages of your internet browser:

For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050

For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835

For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

For the Safari web browser, please visit this page from Apple: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

For any other web browser, please visit your web browser’s official web pages.

C.  More Information About Cookies

 You can learn more about cookies here: www.allaboutcookies.org.

D.  Contact Us

 If you have any questions about this Cookies Policy, you can contact us:

• By email: info@TechCareerUSA.com

• By visiting this page on our website: TechCareerUSA.com

6.  USE OF YOUR PERSONAL DATA

 We may use Personal Data for the following purposes:

• Performing Service, including but not limited to monitoring the usage of our Site, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, or providing similar services.

• To Manage Your Account: to manage your registration as a user of the The Personal Data you provide can give you access to different functionalities of the Site that are available to you as a registered user.

• For the Performance of a Contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Site.

• To Contact You: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

• To Provide You with: news, advertising and marketing services, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such

• To Manage Your Requests: To attend and manage your requests to

• For Business Transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Site users is among the assets

• Security and Fraud: Helping to ensure security and integrity and prevent fraud.

• Debugging: Debugging to identify and repair errors.

• Legal Reasons: Fulfilling our legal functions or obligations

• For Other Purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Site, products, services, marketing and your experience.

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.

We may share your Personal Data in the following situations:

• Within Our Corporate Family of Companies: We may disclose your Personal Data with other companies within our corporate family for them to use in ways that are consistent with this Privacy Policy.

• With Service Providers: We may share your Personal Data with Service Providers to monitor and analyze the use of our Site, to contact you.

• For Business Transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another

• With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

• With Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.

• With Other Users: when you share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed

• With Your Consent: We may disclose your Personal Data for any other purpose with your

7.  RETENTION OF YOUR PERSONAL DATA

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer time periods.

8.  TRANSFER OF YOUR PERSONAL DATA

Your information, including Personal Data, is processed at the our operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other Personal Data.

9.  DELETE YOUR PERSONAL DATA

 You have the right to delete or request that we assist in deleting the Personal Data that we have collected about you. Our Site may give you the ability to delete certain information about you from within the Site.

You may update, amend, or delete your information at any time by signing in to your Account, if you have one, and visiting the account settings section that allows you to manage your Personal Data. You may also contact us to request access to, correct, or delete any Personal Data that You have provided to us.

Please note, however, that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

10.  DISCLOSURE OF YOUR PERSONAL DATA

 

1. Business Transactions

If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

B.  Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

C.  Other Legal Requirements

 We may disclose your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation.

• Protect and defend our rights or our

• Prevent or investigate possible wrongdoing in connection with the Site.

• Protect the personal safety of users of the Site or the public.

• Protect against legal

11.  SECURITY OF YOUR PERSONAL DATA

The security of your Personal Data is important to us, but remember that no method of transmission over the internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

12.  CHILDREN’S PRIVACY

As a general rule, our Site is designed for a general audience and is not directed to children under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent’s consent before we collect and use that information. Please contact us if you have concerns regarding the potential collection of your child’s information.

13.  LINKS TO OTHER WEBSITES

Our Site may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. We strongly advise you to review the privacy policy of every site you visit because their privacy practices are not covered in this Privacy Policy.

14.  ANTI-CORRUPTION DUE DILIGENCE SUMMARY

This Anti-Corruption Due Diligence Summary describes the types of personal and business information that we collect as part of the anti-corruption due diligence process, how we may use the information, protect it, and with whom we may share it.

A.  Information We Collect and How We Use It

Before engaging any contractor or supplier that falls within the definition of a third party intermediary, we conduct due diligence including the collection of information, the specific purpose of which is to:

(i) assess the anti-corruption risks associated with each potential donation recipient, contractor or supplier (together known as “Candidate”) for compliance with our legal obligations, specifically to determine if a Candidate represents a risk of non-compliance with the Foreign Corrupt Practices Act (FCPA); (ii) evaluate, select, and approve or reject the Candidate; (iii) communicate with Candidates;

• where required, to assess the suitability of suppliers providing specialist services; (v) monitor compliance with our anti-corruption process; and (vi) obtain legal advice from external legal advisers (when applicable). For successful Candidates, these checks will be refreshed every 2 years.

This due diligence will include:

• Completion of a Candidate questionnaire that, where applicable, requires information such as:

• Candidate’s personal and business information (information that personally identifies the Candidate and their business and qualifications).

• Contact information for the individual(s) responsible for the business relationship between Candidate and us, including name, year of birth, country of residence, telephone number and email address.

• Information relating to the services provided.

• Information relating to any sub-contractors, subsidiaries and/or related parties (e.g., partnerships, sister companies, joint ventures), third parties, intermediaries, or other persons or entities the Candidate will engage when providing services, including name, year of birth, country of residence, telephone number and email address.

• Information relating to owners, partners or shareholders of companies Candidate will engage when providing services, including name, year of birth, country of residence, citizenship, ownership percentage and indication of whether they are associated with a government entity or political party or campaign.

• Reference information (company and individual contact information for Candidate’s references);

• Information regarding any formal charges or convictions against the Candidate, its trustees, officers, or its executives, including bribery or corruption related violations.

• Searches on the internet or other public sources of information (e.g. public data registries).

To the extent you have provided personal information about another individual in connection with this questionnaire, you must provide assurance that you have obtained their written consent for us to process their information as outlined within this Privacy Policy and you agree that you will maintain a record of all these consents and provide them upon request.

B.  Information We Share

We may share the information you provide with our domestic and international affiliates for the purposes described above. We will act as the data controller in relation to its compliance activities and will capture the information required for the purposes outlined above.

We may also share the information you supply with third parties who perform services for us or with whom we contract for the purposes described in this Privacy Policy. These third-party service providers are given the information that they need to perform their designated functions and are prohibited from using or disclosing your personal or business information for unrelated business purposes. These service providers are instructed to process the data in accordance with any applicable legal requirements regarding data protection and data security.

We may disclose your information in other special circumstances. These include situations when the sharing is necessary to protect the safety, property, or our other rights, our customers, our associates, or any other person, or where otherwise required by law. For example, we may be required to disclose your information as is required by law pursuant to lawful requests such as subpoenas, court orders, or when we believe disclosure is necessary or appropriate in connection with an investigation of reasonably suspected or actual criminal activity.

C.  Information We Transfer

We may transfer the personal and business information we collect to other countries where we do business, which may not have the same data protection laws as the country in which you reside. We have taken steps to provide an adequate level of protection in accordance with applicable data protection laws in the countries in which we operate.

We may transfer any information we have about you in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of us or as part of a corporate reorganization or stock sale or other change of corporate control.

D.  How We Protect Personal Information

We require that our service providers maintain reasonable administrative and technical security safeguards to protect against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access, use, and other unauthorized or unlawful forms of processing of the personal information you provide.

E.  How Long Do We Keep Your Information

We keep Candidate’s information for as long as it’s required for the purposes described in this Anti-Corruption Due Diligence Summary. Personal information related to due diligence checks, either in hard copy or electronically, is kept for five (5) years or as otherwise required by law or Company policy, from the date that the last related action occurred.

15.  CALIFORNIA RESIDENT’S PRIVACY RIGHTS

This section 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.

A.  What Are the Categories of Personal Information Collected?

We may collect or receive (and may have collected or received during the 12-month period prior to the Last Updated date of this California Resident’s Privacy Rights) the categories of personal information listed below. Not all categories will be collected or received for every individual.

• Identifiers: Personal identifiers, such as name, telephone number, physical address, email address, national identification numbers, driver’s license numbers, and

• Device Information and Online Activity: Device and online identifiers, keystroke patterns indicative of human or bot website/app usage, mobile and web network activity and related information (such as Mac address, IP address, cookie IDs, browser activity, and other information associated with your browsing history), and social media information.
• Commercial Information: Purchase and transaction history information (such as products or services you have purchased, rented, or returned), health and safety-related information, product testimonials, travel and vacation information, and competition entries.

• Communications: Communication details (such as the content of emails, text messages, or other communications), call logs, and calendar information where we are a party to the exchange.

• Demographic Information: Demographic information, such as age (including information about children under the age of 13 with respect to certain purchases and services, gender, citizenship, ethnicity, date of birth, family or marital status, household income, education, professional and employment information, and family health.

• Financial Information: Financial information, such as credit or debit card numbers, financial account numbers, and claims information.

• Geolocation: Location information, such as geolocation information.

• Background Information: Background and criminal information, such as background checks and criminal convictions.

• Inferences: Individual preferences and characteristics, such as inferences related to shopping patterns and behaviors

• Sensitive Personal Information: Government-issued identifiers (such as social security, driver’s license, state identification card, or passport number), account log-in and financial information (such as payment card details), and precise geolocation.

B.  What Are the Categories of Sources from Which We Collect Your Personal Information?

 We may obtain and combine personal information from different sources, as described in the Privacy Policy and provided below:

• Provided directly by you or a member of your household.

• Collected from a Device associated with you or your household.

• Collected from another company within our family of companies.

• Collected from an external third-party source.

• Collected from another solution or asset.

• Collected from other sources, when it is appropriate, to help us correct or supplement our records, improve the quality or personalization of our services, increase the appeal and relevance of advertising, and to prevent or detect fraud.

C.  What Are the Purposes for Collecting Personal Information?

We may use your personal information for the purposes described in the Privacy Policy and as provided below:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services.

• Providing advertising and marketing services, including targeted

• To conduct auditing and monitoring of transactions and engagement, including auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.

• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us.

• Helping to ensure security and integrity and prevent fraud.

• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them.

• Debugging to identify and repair errors.

• To conduct business analysis, such as analytics, projections, identifying areas for operational

• To conduct research and development, including undertaking internal research for technological development and demonstration.

• To fulfill our legal function or

We use sensitive personal information for each of the purposes described above and to make inferences about customers, which we may use to promote certain products or services.

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.

D.  Sale and Sharing of Personal Information

We may sell or share personal information with third parties for various purposes including cross-context behavioral advertising or sharing among our affiliated entities. These kinds of disclosures may be deemed selling or sharing personal information under California law and you have the right to opt out of these disclosures. We may sell or share for cross-context behavioral advertising purposes (and may have sold or shared during the 12-month period prior to the Last Updated date of this California Resident’s Privacy Rights) the following categories of personal information to the following categories of third parties:

Category of Personal Information Sold or Shared	Category of Third-Party Recipient
Identifiers	Service Providers (such as advertising networks, marketplace sellers, analytics providers, etc.)
Device Information and Online Activity	Business partners that receive data for their own

	independent use and not to provide services to us
Demographic Information	●         Business partners that receive data for their own independent use and not to provide services to us ●         Service Providers that receive data to provide services to us (e.g., analytics providers, advertising networks, cloud storage providers, etc.) ●         Business partners
Geolocation	Business partners that receive data for their own independent use and not to provide services to us
Inferences	●         Business partners that receive data for their own independent use and not to provide services to us ●         Service Providers that receive data to provide services to us (e.g., analytics providers, advertising networks, cloud storage providers, etc.) ●         Business partners

E.  Sale or Share of Personal Information of Consumers under 16 Years of Age

We do not knowingly sell or share (for cross-context behavioral advertising) the personal information of consumers under 16 years of age. For more information about treatment of children’s personal information, see the Privacy Policy.

F. Disclosing Personal Information for Business Purposes

During the 12-month period prior to the Last Updated date of this California Resident’s Privacy Rights, we may have disclosed your personal information with certain categories of third parties as described in the Privacy Policy and disclosed below:

• Demographic information
• Device and online identifiers
• Financial information
• Individual preferences and characteristics
• Location information
• Personal identifiers
• Purchase history information
• Background and criminal information
• Characteristics of protected classifications under California or federal law
• Education information
• Employment information

• Government identifiers
• Health and health insurance information
• Internet, application, and network activity

G.  How Long Do We Retain Your Personal Information?

We will keep the personal information we collect about you for as long as necessary to carry out the purposes set forth in this Privacy Policy or any other notice provided at the time of data collection, but no longer than as required or permitted under applicable law or our internal policy. We dispose of the information we collect in accordance with our retention policies and procedures.

H.  What Are Your California Privacy Rights?

If you are a California resident, you can make certain requests regarding your personal information, and we will fulfill each request to the extent required by law. If we are unable to comply with your request in whole or in part, we will notify you with reasons for the denial.

As stated in more detail below, you can request that we:

• Provide you with access to a copy of and certain details regarding the personal information we have about you.

• Delete your personal information.

• Stop selling your personal information or sharing your personal information for cross-context behavioral advertising.

• Correct your inaccurate personal information.

• Limit the use or disclosure of your sensitive personal information (SPI).

To exercise any of these privacy rights, please contact us.

I.  Request to Access My Personal Information

You have the right to request access to the personal information we may have collected about you. To access your personal information, please contact us.

Requests to access your personal information may be submitted up to two times in a rolling twelve-month period. In response, we will return to you the following categories of information, to the extent required by law:

• The categories of personal information we have collected about you.

• The categories of sources from which we collect your personal information.

• The business or commercial purpose for collecting, selling, or sharing your personal

• The categories of third parties to whom we disclose personal information.

• The specific pieces of personal information we have collected about you.

• A list of categories of personal information that we have sold or shared for cross-context behavioral advertising, along with the categories of third parties we sold it to or shared it with for cross-context behavioral advertising.

• A list of categories of personal information that we have disclosed for a business purpose, along with the categories of third parties we disclosed it to.

J.  Delete My Personal Information

You have the right to ask that we delete your personal information. Once we receive a request, we will delete the personal information (to the extent required by law) we hold about you as of the date of your request from our records and direct our Service Providers to do the same. Choosing to delete your personal information may impact your ability to use our websites and online features, including closure of your online account, and limit your use of in-store functions that require your personal information. To delete your personal information, please contact us.

K.  Stop Selling or Sharing My Personal Information

You have the right to opt-out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising and can request that we stop by contacting us.

Your opt-out request may be processed differently depending on whether you are logged into your account. If you are logged in, your preference will be associated with your account, and the Device on which you exercised your choice. When you log in from another device or browser, it too will be automatically opted out. If you are not logged into your account, your request will only be associated with that one browser. We also support your use of the Global Privacy Control (GPC). If you notify us of your privacy preferences through GPC, we will honor your request with respect to the browser or device that sends us the GPC signal, and when you login to your account from that device, the opt-out will extend to your account, as well.

If you change your preference from opt-in to opt-out, you may be asked to confirm your preference prior to it taking effect. After opting out of the sale of your personal information or sharing of your personal information for cross-context behavioral advertising, you may still receive ads from us, however they will not be tailored to you.

L.  Correct My Personal Information

You have the right to ask that we correct the personal information we may have collected about you if that information is inaccurate. We reserve the right to request identifying documentation from you in certain circumstances, as permitted by law. To correct your personal information, please contact us.

M.  Limit the Use and Disclosure of SPI

You have the right to ask that we limit our use and disclosure of your SPI to certain purposes permitted by law and can do so by contacting us.

We will not discriminate against you for exercising your rights. We will not deny you goods or services, charge different prices or rates, provide a different level of service or quality of goods, or suggest that you might receive a different price or level of quality for goods. Some programs or membership services require usage of personal information to function, so compliance with your request may impact those experiences.

N.  How Do We Verify Your Identity to Complete Your Access, Correction and Deletion Requests

If you request access to, or the correction or deletion of, your personal information we will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your:

• First name, middle initial (if applicable), last name
• Address
• Email address
• Phone number

When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. Third-party identification services may help us with verification to prevent disclosure of your personal information resulting from fraudulent requests. In the event more documentation is necessary to verify your identity, we will notify you directly.

O.  What If You Can’t Verify My Identity?

If we can’t verify your identity, we will notify you, and your request(s) to access, request, or delete your personal information may not be processed. Any requests may be denied if we have reason to believe they are fraudulent.

P. How Do I Submit a Request Using an Authorized Agent?

If you would like an authorized agent to exercise your rights for you, they may use the same links described above to submit requests. We require documentation demonstrating your agent’s authority to submit requests on your behalf. For example, a valid power of attorney or other documentation, including a letter, signed by you (the California resident) authorizing the agent to submit your requests. You can download a sample letter from the request form. Documentation may be uploaded at the time you submit your request to our email at info@TechCareerUSA.com. If you submit your request by calling, you can email your forms to info@TechCareerUSA.com.

Q.  Number of Requests Received

 To view metrics about our privacy requests, please contact us.

R.  Shine the Light

 California residents also have the right to request that we provide you with: (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year; and (b) the identity of those third parties. To exercise this right, please contact us.

S.  Notice of Financial Incentive

If we provide a financial incentive, we will provide you with the details, including how the incentive is related to your data before you participate so that you may make an informed decision about whether and how to participate. In the event you decide to take advantage of a financial incentive, you will always have the right to withdraw from participation and we will provide you with directions on how to do so.

T. Contact Us

 If you have any questions about this California Resident’s Privacy Rights, you can contact us:

• By email: info@TechCareerUSA.com

• By visiting this page on our website: TechCareerUSA.com

16.  COLORADO RESIDENT’S PRIVACY RIGHTS

 This section applies solely to Colorado consumers who interact with us in an individual or household capacity. This section uses certain terms that have the meaning given to them in the Colorado Privacy Act (the “CPA”).

A.  Collection, Use and Sharing of Personal Data

 We may collect, use and share Personal Data as described in the chart below. For more information on the categories of personal data we collect, please see the Privacy Policy.

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
Identifiers	●         Conducting business analysis ●         Conducting research and development ●         Fulfilling our legal functions or obligations	No	●         Service Providers (such as advertising networks, analytics providers, etc.) Business partners that provide services to us but also uses for their own purposes
	●         Helping to ensure security and integrity and prevent fraud ●         Performing and providing advertising and marketing services		●         Business partners that receive data for their own independent use and not to provide services to us

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
	●         Performing services ●         To conduct auditing and monitoring of transactions and engagement ●         Undertaking activities to verify or maintain the quality or safety of our services or devices
Device and Online Identifiers	●         Conducting business analysis ●         Conducting research and development ●         Debugging to identify and repair errors ●         Fulfilling our legal functions or obligations ●         Helping to ensure security and integrity and prevent fraud ●         Performing and providing advertising and marketing services ●         Performing services ●         To conduct auditing and monitoring of transactions and engagement ●         Undertaking activities to verify or maintain the quality or safety of our services or devices	Yes	●         Business partners that receive data for their own independent use and not to provide services to us ●         Service Providers (such as advertising networks, analytics providers, etc.)
Internet and Other Network Activity Information	●         Conducting business analysis ●         Conducting research and	No	●         Service Providers (such as advertising networks, analytics providers, etc.)

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
	development ●         Fulfilling our legal functions or obligations ●         Helping to ensure security and integrity and prevent fraud ●         Performing and providing advertising and marketing services ●         To conduct auditing and monitoring of transactions and engagement
Commercial Information	●         Conducting research and development ●         Fulfilling our legal functions or obligations ●         Performing and providing advertising and marketing services ●         Performing services ●         To conduct auditing and monitoring of transactions and engagement ●         Undertaking activities to verify or maintain the quality or safety of our services or devices	Yes	●         Service Providers that receive data to provide services to us (e.g., analytics providers, advertising networks, cloud storage providers, etc.) ●         Business partners that receive data for their own independent use and not to provide services to us
Communications	●         Conducting business analysis ●         Conducting research and development ●         Fulfilling our legal functions or obligations	No	●         Service Providers (such as advertising networks, marketplace sellers, analytics providers, etc.) ●         Business partners that receive data for their

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
	●         Helping to ensure security and integrity and prevent fraud		own independent use and not to provide services to us
	●         Performing and providing advertising and marketing services
	●         Performing services
	●         To conduct auditing and monitoring of transactions and engagement
	●         Undertaking activities to verify or maintain the quality or safety of our services or devices
Demographic Information (certain of which may include sensitive data as defined by the CPA)	●         Conducting business analysis ●         Conducting research and development ●         Fulfilling our legal functions or obligations ●         Helping to ensure security and integrity and prevent fraud	Yes	●         Service Providers (such as advertising networks, marketplace sellers, analytics providers, etc.) ●         Business partners that receive data for their own independent use and not to provide services to us
	●         Performing and providing advertising and marketing services
	●         Performing services
	●         Recruiting and employment purposes
	●         To conduct auditing and monitoring of transactions and engagement

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
	●         Undertaking activities to verify or maintain the quality or safety of our services or devices
Financial Information	●         Conducting business analysis ●         Conducting research and development ●         Fulfilling our legal functions or obligations ●         Helping to ensure security and integrity and prevent fraud ●         Performing and providing advertising and marketing services ●         Performing services ●         Recruiting and employment purposes ●         To conduct auditing and monitoring of transactions and engagement ●         Undertaking activities to verify or maintain the quality or safety of our services or devices	No	●         Service Providers (such as advertising networks, marketplace sellers, analytics providers, etc.) ●         Business partners that receive data for their own independent use and not to provide services to us
Geolocation	●         Conducting business analysis ●         Conducting research and development ●         Fulfilling our legal functions or obligations ●         Helping to ensure security	No	●         Service Providers (such as advertising networks, marketplace sellers, analytics providers, etc.) ●         Business partners that receive data for their own independent use and not to provide

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
	and integrity and prevent fraud ●         Performing and providing advertising and marketing services ●         Performing services ●         Recruiting and employment purposes ●         To conduct auditing and monitoring of transactions and engagement ●         Undertaking activities to verify or maintain the quality or safety of our services or devices		services to us

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
Background Information	●         Conducting business analysis ●         Conducting research and development	No	●         Service Providers (such as advertising networks, marketplace sellers, analytics providers, etc.)
	●         Fulfilling our legal functions or obligations ●         Helping to ensure security and integrity and prevent fraud		●         Business partners that receive data for their own independent use and not to provide services to us
	●         Performing and providing advertising and marketing services
	●         Performing services
	●         Recruiting and employment purposes
	●         To conduct auditing and monitoring of transactions and engagement
	●         Undertaking activities to verify or maintain the quality or safety of our services or devices
Inferences	●         Conducting business analysis ●         Conducting research and development	Yes	●         Business partners that receive data for their own independent use and not to provide services to us
	●         Fulfilling our legal functions or obligations ●         Helping to ensure security and integrity and prevent fraud		●         Service Providers that receive data to provide services to us (e.g., analytics providers, cloud storage providers, etc.)
	●         Performing and providing advertising and marketing

Category of Personal Data	Processing Purpose(s)	Used for Targeted Advertising?	Sold or Shared
	services ●         Performing services ●         Recruiting and employment purposes ●         To conduct auditing and monitoring of transactions and engagement ●         Undertaking activities to verify or maintain the quality or safety of our services or devices

Processing Purposes:

• Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage or providing similar services.

• Performing and providing advertising and marketing services, including targeted

• To conduct auditing and monitoring of transactions and engagement, including auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance.

• Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us.

• Helping to ensure security and integrity and prevent fraud.

• Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them.

• Debugging to identify and repair errors.

• Conducting business analysis, such as analytics, projections and identifying areas for operational improvement.

• Conducting research and development, including undertaking internal research for technological development and demonstration.

• Fulfilling our legal functions or obligations.

• Recruiting and employment purposes.

We do not knowingly process personal data from children under the age of 13. We also do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers, as defined in the CPA.

B.  Your Colorado Privacy Rights

If you are a Colorado consumer who interacts with us in an individual or household capacity (and not in a commercial or employment context), you may have the right to: (1) request access to, correction of or deletion of your personal data; and (2) opt-out of the processing of your personal data for purposes of targeted advertising or the sale of your personal data. In addition, you may have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal data to another entity.

C.  How to Submit a Request

To request access to, correction of or deletion of your personal data, please contact us. To opt-out of the processing of your personal data for purposes of targeted advertising or the sale of your personal data, please contact us.

To submit an opt-out request as an authorized agent on behalf of a consumer, please contact us. If you submit a request through an authorized agent, we may ask for your written permission or a power of attorney. Where you provided your authorized agent with written permission, we may require that you also verify your identity.

D.  How We Verify Your Identity To Complete Your Requests

 If you request access to, or the correction or deletion of, your personal information we will verify your identity before disclosing the requested information. To do so, we may ask that you log into your account or provide us with your:

• First name, Middle initial (if applicable), Last name
• Address
• Email address
• Phone number

When you make a request, you will be asked to answer a few questions about yourself to help us verify your identity. Third-party identification services may help us with verification to prevent disclosure of your personal information resulting from fraudulent requests. In the event more documentation is necessary to verify your identity, we will notify you directly.

E.  How to Submit an Appeal

You may appeal our decision with respect to a request you have submitted by contacting us.

F. Contact Us

If you have any questions about this Colorado Resident’s Privacy Rights, you can contact us:

• By email: info@TechCareerUSA.com

• By visiting this page on our website: TechCareerUSA.com

17.  CONNECTICUT RESIDENT’S PRIVACY RIGHTS

 Connecticut residents can exercise the following rights by contacting us::

• Request to Access My Personal Data.
• Delete My Personal Data.
• Correct My Personal Data.
• Opt Out of the Processing of My Personal Data for Purposes of Targeted
• Opt Out of the Sale of My Personal Data.

If we decline to take action on one of your rights as a Connecticut resident, you can submit an appeal by contacting us.

18.  VIRGINIA RESIDENT’S PRIVACY RIGHTS

 Virginia residents can exercise the following rights by contacting us:

• Request to Access My Personal Data.
• Delete My Personal Data.
• Correct My Personal Data.
• Opt Out of the Processing of My Personal Data for Purposes of Targeted
• Opt Out of the Sale of My Personal Data.

If we decline to take action on one of your rights as a Virginia resident, you can submit an appeal by contacting us.

19.  RESPONSIBLE DISCLOSURE POLICY

 

1. Responsible Disclosure

We care about maintaining the trust and confidence that our customers place in us. The security of our online platforms is of paramount importance. If you are a security researcher and have discovered a security vulnerability in one of our services or sites, we encourage you to disclose it to us in a responsible manner. We will engage with security researchers when vulnerabilities are reported to us in accordance with this Responsible Disclosure Policy. We will validate and fix vulnerabilities in accordance with our commitment to security and privacy.

We will not take legal action against, or suspend or terminate the accounts of, researchers who discover and report security vulnerabilities in accordance with this Responsible Disclosure Policy. We reserves all legal rights in the event of any non-compliance.

B.  Reporting

We encourage security researchers to share the details of any suspected vulnerabilities with the our security team by contacting us. We will review the submission to determine if the finding is valid and has not been previously reported. At our sole discretion, you may be eligible for monetary compensation for your efforts. Our employees, vendors currently working with us, or residents of countries on the U.S. sanctions list are not eligible for monetary compensation. In case you belong to any of the listed categories, you must specify this information in your report. We require security researchers to include detailed information with the specific steps involved for us to reproduce the vulnerability.

If you identify a valid security vulnerability in compliance with this Responsible Disclosure Policy, we will:

• Work with you to understand and validate the issue
• Address the risk (if we deem it to be appropriate for addressing)

C.  Noncompliance

Public disclosure of the submission details of any identified or alleged vulnerability without our express written consent will deem the submission as non-compliant with this Responsible Disclosure Policy. In addition, to remain compliant you are prohibited from:

• Accessing, downloading, or modifying data residing in an account that does not belong to you.

• Executing or attempting to execute any “Denial of Service” attack.

• Posting, transmitting, uploading, linking to, sending, or storing any malicious software.

• Testing in a manner that would result in the sending unsolicited or unauthorized junk mail, spam, pyramid schemes, or other forms of unsolicited messages.

• Testing in a manner that would degrade the operation of any our

• Testing third-party applications, websites, or services that integrate with or link to our

Please contact us if you have a security issue you wish to report to our security team.

20.  CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. Please check our Privacy Policy on this page periodically for changes. Changes to this Privacy Policy are effective when they are posted on this page.

21.  CONTACT US

If you have any questions about this Privacy Policy, you can contact us:

• By email: info@TechCareerUSA.com

• By visiting this page on our website: TechCareerUSA.com