Privacy Policy

This page was last updated on February 2, 2023. Please note that this privacy policy (“Privacy Policy”) may change from time to time. Such changes are effective upon posting and will be communicated on our website under this Privacy Policy section.

This website https://www.thetustingroup.com/ (the “Website”) is operated by The Tustin Group (the “Client”) located at 2555 Industry Lane, Norristown, PA 19403. The Tustin Group is committed to respecting its clients and partners privacy and protecting your personal information (“Personal Information”) it collects or maintains. This Privacy Policy should be read carefully and together with our Cookies Policy and Data Request.

The Tustin Group is certified with the U.S. Department of Commerce’s Safe Harbor Program and adheres to U.S.-EU Safe Harbor framework principles for the protection of PII transferred from the EU to The Tustin Group’s data processing locations.

Scope

This privacy policy sets forth the principles that The Tustin Group adheres to with regard to the collection, protection and online and offline transfer of Personal Information processed by The Tustin Group.

Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, such as your name, address or email address. Personal Information does not include information that has been reported in the aggregate, or publicly available that has not been combined with non-public Personal Information.

Personal Information Collected

The Tustin Group may collect Personal Information and demographic information from you directly, such as online through your use of our Website (please see the Cookies section below), that you chose to provide us via our Website. The Tustin Group also receives, stores and processes Personal Information provided by you both online and offline. Personal Information The Tustin Group collects may be: name, email address, phone number.

Use of Personal Information

The Tustin Group may use Personal Information collected via the Website for the following purposes:

• To ensure that the Website is presented to you in an effective manner;
• To provide you with information that you have requested from The Tustin Group;
• Where you have registered with The Tustin Group, to send you electronic and/or paper form marketing and other materials relating to The Tustin Group’s services, unless you would prefer The Tustin Group not to do so;
• To monitor and analyze trends, usage, and activities in connection with the Website and to improve the Website and products and services The Tustin Group offer; and
• To service your order, where appropriate for, which it was provided or as otherwise required to provide The Tustin Group’s services.

The Tustin Group uses third party analytics services to help analyze and track data, determine the popularity of certain content, and provide statistical information about users of the Website.

The Tustin Group’s Disclosure/Transfer of Personal Information with Third Parties

The Tustin Group does not share, rent, sell or exchange Personal Information submitted via the Website with third parties, except in the following instances:

• You have consented or directed The Tustin Group to share your Personal Information with third parties;
• Sharing Personal Information is ordered by a court, required by law, or is otherwise permitted by applicable law;
• The Tustin Group reasonably believes that your actions are inconsistent with The Tustin Group’s agreements or policies or that you have violated the law;
• The Tustin Group has a good faith belief that access, preservation or disclosure of such Personal Information is reasonably necessary to protect the rights, property or safety of The Tustin Group, its clients, partners, Website users or the public;
• Sharing with The Tustin Group’s professional advisors is necessary to obtain advice or otherwise protect and manage The Tustin Group’s business interests; and
• The Tustin Group, or substantially all our The Tustin Group’s assets are merged into or acquired by a third party, in which case your personal information may be transferred as part of the merger or acquisition.

The Tustin Group will only transfer Personal Information to a third party where the third party has provided assurance that it will provide at least the same level of security and protection as prescribed by this privacy policy. When legally required, The Tustin Group will provide both notice of The Tustin Group’s intent to process your Personal Information and your choice to opt-out of future processing of such information. The Tustin Group also processes Personal Information on behalf of and as instructed by you. The Tustin Group does not own, control or have the right to disclose or modify such information. The Tustin Group does not disclose Personal Information provided to The Tustin Group by you or other clients and partners, except at your or their direction.
Personal Information submitted to The Tustin Group is only available to The Tustin Group employees or agents The Tustin Group has determined reasonably needs access to such Personal Information in order to provide services to you or carry out the purpose(s) for which it was collected.

Cookies

The Tustin Group may use cookies to track your web use and enable access to various features on the Website and Personal Information may be stored in these cookies. A cookie is a small piece of text sent to your browser by a website you visit. It helps the website to remember information about your visit, like your preferred language and other settings, that can make your next visit easier and the site more useful to you. Most computer users have the option of setting their computer preferences to not accept any cookies. Any Personal Information contained within a cookie will be treated with the same level of protection as other Personal Information collected and maintained by The Tustin Group.

How does The Tustin Group use cookies?

The Tustin Group’s use of cookies is explained in detail in The Tustin Group’s (LINK TO CLIENT Cookie Policy). This Website may use the following types of cookies:

• Essential Cookies – these cookies are necessary for the Website or a particular service or feature you request to function
• Marketing Cookies — these cookies may be set on the Website by advertising partners to understand your interests and help show you relevant advertisements or other content
• Performance Cookies — these cookies help The Tustin Group to understand how you interact with The Tustin Group’s site

Information Integrity and Security

The Tustin Group has implemented physical, procedural, and technical safeguards to prevent unauthorized access to or disclosure of Personal Information, to protect data accuracy, and to ensure appropriate use of such information, whether in electronic or hard copy form.

Information Storage

By providing information via the Website or any The Tustin Group service, you consent to the storage and processing of your information, including, but not limited to, Personal Information.

California Privacy Notice Supplement

The CCPA (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their Personal Information. This Privacy Notice for California Residents supplements the information contained in The Tustin Group’s Privacy Notice and applies solely to individuals who reside in the State of California (“consumers” or “you”).
The Tustin Group does not sell your personal information.

Personal information The Tustin Group collects

The Tustin Group collects various types of personal information, as explained in the “Personal Information Collected” section above. In particular, during the last 12 months, The Tustin Group has collected the following categories of personal information from the website: identifiers (e.g., name and email), professional and employment-related information and education information (e.g., job title or curriculum vitae), commercial information (e.g., products purchased and billing and delivery information where we offer goods for sale), internet or other electronic network activity information (e.g., IP address or browser properties), and inferences The Tustin Group derive from other information we collect. The Tustin Group collects this information for the business and commercial purposes described in the above section titled “Use of Personal Information.”

Personal information we share

In the preceding 12 months, The Tustin Group has disclosed the following categories of personal information for business purposes to the following categories of recipients:

Your rights

Subject to certain limitations, you, or your appropriately-verified authorized agent, have the right to request the following information from us:

• The categories of personal information we collect about you.
• The categories of sources from which your personal information is collected.
• The business purpose for collecting your personal information.
• The categories of third parties with whom we share your personal information.
• The specific pieces of personal information we have collected about you.

Additionally, subject to certain limitations, you have the right to request deletion of your personal information. The Tustin Group will not charge for this service.

The Tustin Group will not discriminate against you if you choose to exercise any of your rights under the CCPA.

If you wish to exercise your rights under the CCPA, you contact us via the information listed in the Contact Information section.

Contact Information

If you have any comments, questions, or concerns about our privacy practices or wish to exercise your rights under the CCPA please contact us at augusto@grandmarketingsolutions.com. The Tustin Group may ask you a series of questions to help confirm your identity, such as information related to your recent interactions with The Tustin Group, before disclosing any specific information. To the extent that access rights pertain to data that The Tustin Group does not own or have the right to disclose or modify, The Tustin Group will make a reasonable effort to identify and notify the relevant data owner of your request. If The Tustin Group receives your request from an authorized agent, The Tustin Group will not disclose any information to such authorized agent until The Tustin Group has confirmed said agent’s authority with you. As such, The Tustin Group may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please email The Tustin Group at augusto@grandmarketingsolutions.com.

Children

The Tustin Group’s Website is not intended for and should not be used by children under 13 years old. Please inform us if you are aware of any Personal Information associated with a child entered via The Tustin Group’s Website so we may delete it.

Links to Other Websites

The Tustin Group’s Website may present links for access to other websites. Please be aware The Tustin Group is not responsible for the content or privacy practices of those websites. The Tustin Group encourages you to carefully review the privacy policy of each website you visit.