Privacy Policy

TPC Wire and Cable (“we,” or “us”) respects your privacy and is committed to protecting personal information. This Privacy Policy (the “Policy”) explains our privacy practices for information we collect and use about website visitors and customers. This Policy applies to information we collect through our website, www.tpcwire.com (the “Site”), and through interactions with customers and job applicants. It describes how we collect, use, and share such information, and certain rights and options website visitors and customers may have regarding their information. Use of our Site is also subject to our Terms of Use, which are available here. 

We reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information. 

By providing us with personal information or using our website, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use our website or provide us with your information. 

INFORMATION WE RECIEVE 

1.  Personal Information
   For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. The types of personal information we may collect through can be grouped as follows:   

• Contact information – first name, last name, email address, position, name and mailing address of your organization, billing address, and telephone number.  
• Customer account information – customer ID, account username, account password, account number, and other information that we may request or that you may provide relating to your account.  
• Transactional information – details about your organization’s transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to the services purchased by your organization.  
• Marketing information – details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.  
• Communication information – copies of communications and inquiries you have submitted to us, including through email, calls, and features available on our Site.  
• Job applicant information – contact information, information regarding your qualifications and background, educational information, and any other information you provide as part of your application if you apply for a job via our Site.  
• Device and usage information – details regarding how and when you use our Site, including the device used to connect to our Site, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our Site, and information about your interaction with our Site. 
  
  We collect this information when you visit or navigate our Site, fill in forms on our Site, submit orders or engage in transactions with us, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, pay an invoice, or otherwise provide us with personal information. 
  
  Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”  We may also collect information about you from third-party sources and information about you that is publicly available.    
2.  Automatically Collected Usage and Device Information
   Like most websites, our Site uses various technologies to automatically collect information about visitors.  Those technologies include:      
• Cookies.  Cookies are small text files that a website transfers to a visitor’s device for record keeping purposes.  We use cookies to personalize visitors’ experiences on our website, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our Site traffic.   For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org.  Please note that if cookies are disabled, you may not be able to enjoy certain features of our Site.  
• Log Files and Device Identifiers.  We use log files to track actions occurring on the Site and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.  
• Web beacons and other technologies.  Our App may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users.  Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.  
• Analytics.  Our Site may also use third-party analytics tools such as Google Analytics.  You can find more information about how data is collected and processed in connection with the Google Analytics service here.  You can also read Google’s privacy policy here. 
  
  The information collected through these technologies may be combined with personal information or aggregated with other information on Site visits.  We may share information about your use of our Site with our advertising and analytics partners, who may combine it with other information that you previously provided to them.  
3.  Information from Other Sources
   We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to other information we have collected.  We, and the third parties we engage, may combine information we collect from you over time, and across the Site, with information obtained from other sources.  This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.  
4.  Social Media
   If you interact with us on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (b) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts.  Social media platforms operate independently from TPC Wire and Cable and we are not responsible for the personal information that you choose to submit or link on any social media platform.  We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.  

HOW WE USE PERSONAL INFORMATION 

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:   

• Negotiating, entering into, and managing our business relationship and agreements with your organization, including providing our services and processing payments from your organization.    

• Providing and optimizing your experience on our Site and ensuring that our content is presented to you in the most effective manner.   
• Responding to your inquiries and communicating with you, including regarding our products and services, our agreements with your organization, and other issues.  
• Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.  
• Managing customer service issues, including issues relating to the performance of our products and services, as well as customer feedback.  
• Developing, updating, and improving our products and services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding customers.  

• Processing your job application, including communicating with you regarding your application.   
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Site or the purchase or use of our services.  
• Enforcing our agreements with customers, complying with our legal or regulatory obligations, and defending or advancing legal claims.  
• Notifying you about changes to our Site, services, or material changes to this Policy.  
• Providing you with surveys or otherwise soliciting feedback from you.  

• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.  

For more information about your options relating to your personal information and your communication preferences, see “Choices About the Collection and Use of Personal Information” below.  

OUR MARKETING EFFORTS 

We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our products, services, and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.  

DISCLOSURE OF PERSONAL INFORMATION  

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.  

In addition, we may share your information with the following types of entities:  

• Business partners, service providers, and third-party vendors necessary for the performance of any contract we enter into with you. For example, your information may be shared with our payment processing providers on the Site.  
• Service providers we use to facilitate our business operations and administration. These third parties have access to your personal information only to perform specific tasks on our behalf. Such service providers include, for example, IT and system administration providers and data storage providers.  
• Marketing and advertising vendors that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.  

• Analytics vendors in order to understand our Site traffic and usage patterns, optimize our Site, and identify potential new clients.  
• Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.  
• Our professional advisors, such as lawyers, accountants, and other similar advisors.  
• Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.  
• Other parties for any purpose we disclose at the time you provide the information.  

PROTECTION OF PERSONAL INFORMATION 

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.  

YOUR CHOICES ABOUT PERSONAL INFORMATION  

We respect your right to make choices about the ways we collect, use, and disclose your information.  We try to offer you meaningful choices regarding your personal information.  Some choices you have regarding personal information include the following.  

• Marketing Emails – As required by applicable laws, you can opt out of receiving promotional emails from us by clicking the “unsubscribe” link in any such promotional emails and following the instructions provided. Note that we may still send you emails that confirm your organization’s business transactions with us.  

• Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies.  Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same.  Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Site.  
• Google Analytics – As discussed above, we use Google Analytics in connection with the Site.  If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use.  You can find more information on how Google uses information it collects here. 
• Interest-Based Advertising – To opt-out of personalized or interest-based advertisements, you may be able to adjust the settings on your device.  Please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, has its own instructions on how to prevent the delivery of interest-based advertisements. (We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each mobile platform, not us.). For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.  You can also visit https://optout.aboutads.info to opt out of interest-based advertisements. 
• Declining to Provide Information – You can choose not to provide us with information we may request through our Site, but that may result in you being unable to use certain features of our Site, request information about our Services, or initiate other transactions with us  
• Do Not Track Mechanisms – Please note that our Site does not honor “Do Not Track” signals, and such signals will not impact the operation of this Site.    

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.  

LINKS TO THIRD-PARTY WEBSITES  

Our Site may contain links to third-party websites.  Such websites have separate privacy policies that you should review.  We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.  

RIGHTS AFFORDED TO CERTAIN INDIVIDUALS  

1.  EU / UK / Switzerland Residents
   1.  Rights Under GDPR The European Union’s General Data Protection Regulation and United Kingdom and Switzerland’s versions of the same (collectively, the “GDPR”) afford certain rights to individuals in the European Union, UK, or Switzerland (collectively “EEA”).  If you are in the EEA, you have the following rights.  Note, however, that not all rights apply in all circumstances.
      • Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you  
      • Right to rectify your personal information: if you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).  
      • Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.  
      • Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.  
      • Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.  
      • Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.   

      With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR.  As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to customerservice@tpcwire.com.  This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond.  Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months.  Please note that we may need to request specific information from you to help us confirm your identity.  If you are located in the EEA and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA.    

       

   2. Lawful Basis under GDPR  

      We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so.  We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.

       

      Purpose/Activity	Type of Information	Basis of Processing
      To enter into and subsequently to manage our business relationship with you including: Negotiating, entering into, and performing agreements with your company Responding to inquiries and providing customer support and service Managing and processing transactions for our services Notifying you about changes to our website, business terms, or this Policy Communicating with you and responding to your inquiries regarding our services, agreements with your company, and other issues Process your company credit application and open a credit account for your company	Contact Information Transactional Information Communications Information Company Credit Information	Necessary for our legitimate interests (to manage our business relationships and administer our operations including through the keeping of appropriate records) Performance of a contract with you Necessary to comply with legal obligations
      To administer and protect our business and website including:  Maintaining business records for legal purposes and to comply with tax requirements  Defending and advancing legal claims   Enforcing our rights under any agreements  Ensuring effective security for our services and website  Conducting website maintenance    Identify and address security risks and unlawful activity	Contact Information Transactional Information Communications Information Device and Usage Information	Necessary for our legitimate interests (running our business, facilitating administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)  Necessary to comply with legal obligations
      To make decisions about how best to deliver relevant website content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing efforts	Marketing Information  Transactional Information  Communications Information  Device and Usage Information	Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site)
      To advance and promote our business interests including contacting you regarding services or promotions that may be of interest, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our services, customer service, and marketing efforts	Contact Information  Marketing Information  Transaction Information  Device and Usage Information	Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business)

       

       

       

2. California Residents 

   If you are a California resident, please refer to our “Privacy Notice for California Residents”  for a description of rights available to you under California law.

INTERNATIONAL TRANSFERS

TPC is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located the United States. You understand

and consent that information you provide may be transferred to the United States. You also understand that the data protection laws in the United States may be different from those of the country where you reside. When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.

Specifically, if we transfer personal information from the EEA to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the EU (such as the United States), we will rely on European Commission’s Standard Contractual Clauses (SCCs) as the lawful mechanisms for such transfers. Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors which contain SCCs and define security standards to be employed by each (sub)processors

CHILDREN’S PRIVACY

Our Site is a general audience site and is not directed at, or intended for use by, children under the age of 16 years. Accordingly, we do not knowingly collect personal information from children under age 16. Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.

DATA STORAGE AND RETENTION

We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements. We also consider any specific limitation periods under applicable law.

CHANGES TO THIS POLICY

Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this Site after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.

HOW TO CONTACT US

For questions or more information about our privacy practices, please contact us by e-mail at customerservice@tpcwire.com or by using the contact information provided below:

Attn: IT Director

TPC Wire and Cable

9600 Valley View Road

Macedonia, OH 44056

800 -211-4520

COPYRIGHT

The site and the content within the site are property of TPC Wire and Cable and its subsidiaries and are protected by United States copyright laws and international treaty provisions. These materials may not be copied or redistributed for any purposes without prior written permission from TPC Wire and Cable.