Privacy Policy

1. GENERAL INFORMATION

The following information describes our practices regarding information we collect in relation to visitors to this Website, applicants, and business partners.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

• Maintain business records for analysis and/or audit purposes
• Comply with record retention requirements under the law
• Defend or bring any existing or potential legal claims
• Deal with any complaints regarding the services
• Enforce our commercial agreements

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

Each time you receive an e-mail from us, you will be given the opportunity to “opt-out” or stop receiving them.

If you have any questions regarding our online and data policies, please send an e-mail to info@tharancogroup.com or write us at: Attn: Website Policy Questions, Tharanco Group Inc., 850 Paterson Plank Rd, Secaucus, NJ 07094.

2. VISITOR DATA COLLECTION/USE

You can visit www.tharancogroup.com without actively revealing information that directly identifies you (such as your name, address, telephone number, or e-mail address).  However, certain areas of the Website may prompt you to contact us or provide questions or comments.

We may be required by law to collect certain personal information about you, or it may be necessary for us to collect personal information in order to provide you with the information or materials you request.  If you do not provide this information, we may not be able to meet our obligations.  We will inform you at the time your information is collected whether certain data is compulsory and the consequences of the failure to provide such data.

The categories of information that we may collect data voluntarily provided by you are:

• Personal details (e.g., name, title, employer or organization)
• Contact details (e.g., phone number, email address, postal address or phone number)
• Information that you provide in your communications or interactions with us

We, and third parties, including our service providers, automatically collect the following data using cookies and other device identifying technologies (‘Cookies and Tracking Technologies’):

• Your IP address
• Device ID information
• ISP provider
• Browser type
• Pages and content you view on our Website, Search terms you enter on our Website
• Any other actions you take on our Website

The following table describes the categories of cookies we use and why we use them:

How we use your personal information and the basis in which we use it:

1. We use your personal information to:
   • respond to your communications and requests
   • maintain our relationship with you
   • provide, improve and personalize our Website
   • provide you with the information or materials you request
   • comply with the legal obligations to which we are subject and cooperate with regulators and law enforcement bodies
2. In particular, we process personal information:
   • to fulfil our contractual obligations to you, for example to provide you with information, materials, or services to which you are entitled.  If you do not provide the personal information we need for such purposes, this may prevent or delay the fulfilment of these contractual obligations
   • to comply with our legal obligations, for example to respond to legally binding requests from regulators, law enforcement authorities or other government authorities
   • to meet our legitimate interests, for example:
     • understanding how you use our Website
     • upgrading or improving our Website
     • maintaining information within the business and technical environments in which we operate for purposes of security and efficiency
     • exercising our legal rights where necessary, for example to detect, prevent, and respond to fraud, violations of law, or intellectual property infringement

THG will have no liability for disclosure of your information because of errors in transmission or the unauthorized intervention of third parties.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Policy. We will inform you of the consequences of withholding consent at the time that we ask for your consent.

We may share your personal information with third parties under the following circumstances:

• Service providers and business partners. We may share your personal information with our service providers and business partners that perform business operations for us. For example, we may partner with other companies to maintain our Website or deliver communications to you. We authorize these companies to use your personal information only as necessary to provide these services to us.
• We may share your personal information with our subsidiaries and affiliates, such as GREG NORMAN or Joseph A for the purposes specified in this Policy.
• Law enforcement agencies, courts, regulators, government authorities or other third parties. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party. Where permitted by law or regulation and reasonably practicable, we will attempt to notify you of such requirements.
• Asset purchasers. We may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Policy. You will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information

Your right to access or correct your personal information is subject to applicable legal restrictions. We may take reasonable steps to verify your identity before granting access or making corrections. If we need, or are required, to contact you concerning any event that involves your personal information, we may do so by e-mail, telephone or mail.

Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

If you are located in the European Economic Area (“EEA”) or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to THG in the United States is certified under the EU-U.S. and the Swiss-U.S. Privacy Shield Framework and adheres to the Privacy Shield Principles.

Protecting your personal information is very important to us. THG stores your personal information in a secure location, not accessible to the public. We also restrict access to your personal information to our employees on a need to know basis. We also maintain reasonable physical, electronic, technical, and procedural safeguards to protect your personal information, such as the use of firewalls, encryption for data transfers, and restricted access to data.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal information.

3. EMPLOYMENT APPLICANT DATA COLLECTION/USE

When you apply for a position with the company, we collect information directly from you and from others sources as described below:

We use your personal information to:

• communicate with you with respect to your application, to respond to your questions or requests, and to maintain our relationship with you
• comply with the legal obligations to which we are subject and cooperate with regulators and law enforcement bodies
• process employment applications and enter into employment agreements

In particular, we process personal information:

• to enter into agreements with you, for example to initiate the employment relationship should we decide to hire you. If you do not provide the personal information we need for such purposes, this may prevent or delay the fulfilment of these contractual obligations
• to comply with our legal obligations, for example to respond to legally binding requests from regulators, law enforcement authorities or other government authorities
• to meet our legitimate interests, for example:
  • improving and managing our recruitment process
  • assessing your qualifications for employment
  • information within the business and technical environments in which we operate for purposes of security and efficiency
    exercising our legal rights where necessary, for example to detect, prevent, and respond to fraud, violations of law, or intellectual property infringement

We also collect information about you from other sources, including

• background check information from employment screening agencies or publicly available registers (as allowed by law), or references obtained during recruitment
• publicly available professional profiles on websites or social media (e.g. LinkedIn)
• demographic information (such as education/work histories, academic/professional qualifications, and employment histories)
• personal identification documentation and related information
• human resources data, such as job title and role; and academic and professional qualifications information

We may receive such personal information from current and past employers, employment and recruiting agencies, references, government agencies, educational institutions, certification bodies, and background check providers.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this Policy. We will inform you of the consequences of withholding consent at the time that we ask for your consent.