Effective date: 29 May 2021
Platform: means the website of TCW which may be viewed on your browsing device;
Registered User: means a user that subscribes to our yearly and monthly subscription plan and joins the TCW Circle;
TCW: means The Communications Works that is the handler and enabler of the Platform;
TCW Circle: means The Communications Works Circle, an exclusive member-only club with a paid subscription available to you on the Platform;
Visitor: means a user that is only browsing the Platform without subscribing to our yearly or monthly subscription plan.
Scope of Policy
- use and accessibility
- behavioural advertising and Third Party Sites
- sharing/ disclosure
- opting out
- data security
of any personal information when you visit or use the Platform.
Use of the Platform
Collection of information
The Platform collects information in two (2) ways: actively and passively. We may collect information including personally identifiable information (your full name, e-mail address, phone number) and non-personally identifiable information (e.g. aggregate statistics about what parts of our Platform are most popular).
Active information collection can include both personally identifiable information (e.g., your full name, address, mobile number, email address or similar information that is unique to you) and non-personally identifiable information (e.g., if we were to ask for your first name and a list of the top three things you like about our Platform). Active information is collected from you if you are a Visitor or Registered User in the following manner.
We may ask a Visitor to disclose its full name, e-mail address and a personal message when:
- Visitor requests to download any free brochure, template or checklist available on the Platform;
- Visitor requests for a quotation for any on-going courses on the Platform; or
- Visitor requests to be notified on any new courses which may be made available on the Platform at a later date;
and in all such cases, Visitor grants the Platform permission to send regular e-mails, until such time the Visitor expressly requests to unsubscribe from the e-mail chain, and this request shall not be denied by the us.
We may ask a Visitor to disclose its full name and e-mail address at the time of registration on the Platform, to avail exclusive access to TCW Circle.
At the time of making a payment on the Platform, we shall request you to create a profile on the Stripe payment gateway Platform page. This will require you to submit your e-mail address, full name and credit card or debit card details, and create a unique password. This process shall enable your paid monthly subscription to the Platform. You will also grant us permission to send you e-mails, newsletters and any other document or content as part of your monthly subscription, as well as permission to renew your subscription every month, unless you expressly state to cancel your subscription. We DO NOT collect and do not intend to collect, any financial information, including CVV or credit card pins, from any purchases made by you on the Platform although such information will be stored on a secure server in your personal account on the Platform that is used only for your ease of convenient future purchases. We do not access or use such financial information in any manner.
Passive information may be collected from Visitors and Registered Users. Passive information collection refers to instances in which we collect information from you that you have not actively provided. We may use special technologies to passively collect non-personally identifiable information from Visitors. These technologies allow us to collect certain kinds of non-personally identifiable information, including but not limited to your the type of web browser you use, Internet Protocol (IP) address, time zone, the date and time of your visit, the operating system you use, the specific pages you visit, the address of the website you visited prior to entering the Platform and the cookies that are installed on your device. Additionally, as you browse the Platform, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Platform, and information about how you interact with the Platform. We do not link this passively collected information with personally identifiable information you have actively provided elsewhere on this Platform. We reserve the right to share with third-parties, including our business partners and advertisers, the anonymous (non-personally identifiable) aggregated information that we have passively collected via this Platform.
We collect information identified above, using the following technologies:
- Cookies are data files that are placed on your browsing device (computer, laptop, smartphone or tablet) and often include an anonymous unique identifier. Cookies help us recognise you and your device and store some information about your preferences or past actions. We will ask for your permission to place Cookies or other similar technologies on your browsing device, except where they are essential for us to provide you with a service that you have requested, for example, use of the Stripe payment gateway. You can disable Cookies or manage the Cookies you use on your browsing device at any time. The Cookies we use will only be accessed by us and shall not be accessed by any third-party.
- Google Analytics that is a web-based analytics service offered by Google that tracks and reports website traffic and allows to analyse in-depth detail about the users on our Platform. We may be required to share certain information we collect on the Platform with Google which will be subject to Google’s policies as follows: https://support.google.com/analytics/answer/6004245;
What do we do with the information we collect
The information we collect from you will only be used to:
- provide you with a better browsing experience on the Platform;
- help you conclude the purchase you make on the Platform;
- provide you with the services available through the Platform;
- better communicate with you;
- for purposes of data analysis.
To clarify further, your personal data or your personally identifiable information will not be shared with any third-party nor used for any advertisement purposes.
We may use a function to automatically remember the information you use on our Platform for the following reasons:
- remember information so you will not have to re-enter it during your visit;
- provide custom content and information;
- determine the effectiveness of our Platform.
We may use information we receive, to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of sharing information as follows:
- Opt out of targeted advertising by following these links:
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/
2. Revoke access to e-mail and social network accounts:
Upon request, we may be able to provide you with information about whether we hold any of your personal information by e-mailing us at [email protected] You may choose to disconnect your e-mail account or unsubscribe from our Platform through your account settings. If you no longer have access to your browsing device, you may also contact your e-mail account provider to revoke our access to your account or contact us at [email protected] We will respond to your request within a reasonable timeframe.
3. By e-mailing us:
4. Unsubscribing from marketing communications or mailers:
If you receive marketing communication from us, you can e-mail us and ask that we remove you from receiving marketing communications, or request to unsubscribe. We will cease all communication upon your request and unsubscribe you from the paid subscription provided that such request is received at least fourteen (14) days prior to the date of renewal of subscription. Please remember that if you opt out of receiving marketing communication only you may continue to receive administrative messages from us regarding your purchases on the Platform or for the purposes of daily correspondence with us.
Although we take reasonable steps to protect the personally identifiable information that you provide via this Platform, no system is 100% secure or error-free and neither is the Platform. We do not, and cannot, guarantee the security or accuracy of the information we gather. It is your responsibility to keep your passwords secure. We strongly recommend that you do not share your passwords with any third-party nor store or save them in a manner that may be easily accessed by a third-party. We take the protection of your information very seriously and employ measures through administrative, technical, and physical safeguards designed to protect information against loss, theft, misuse, unauthorised access, disclosure, alteration, and destruction. We encrypt all data in transit through secure socket layer technology (SSL), and other security protocols, including hardware firewalls that are set up on the hosting side. We take reasonable precautions to ensure the integrity and security of our network and systems but cannot guarantee these security measures will prevent third parties from obtaining information by illegal actions or attacks.
This platform is not intended for use by children or minors
This Platform is not directed to and does not seek to collect personally identifiable information from, children under the age of eighteen (18). Nevertheless, if a minor accesses the Platform for any purpose whatsoever, we reserve the right to ask for additional permissions and consents from the parent of the user. For the purpose of this Platform, minor refers to any user under the age of eighteen (18) years. The aforementioned permissions and consents may change from time to time, on our discretion.
Users in European Union
Individuals located in the European Economic Area (EEA) have certain rights in respect of your personal information including:
- the right of access to your personal information;
- the right to correct or rectify any inaccurate personal information;
- the right to restrict or oppose processing of personal information;
- the right to erase your personal information; and
- the right to personal information portability.
We may process your personal information on the basis of contractual necessity to perform a contract we have with you or complete a purchase you have made or are making or are reviewing on the Platform. We may also process your personal information on the basis of our legitimate interests, including analytic reporting and improving the functionality of the Platform. For example, we have a legitimate interest in collecting information about your device hardware and operating system to better understand how users access and use the Platform. We also have a legitimate interest in providing and developing improved artificial intelligence algorithms to deliver better product features to our users.
In some cases, we may process personal information pursuant to legal obligations or to protect your vital interests or those of another person.
How you may exercise your rights as an EEA user on the Platform:
- Right to data portability: users located within the EEA may contact us with questions or requests regarding their personal information using the contact information below. Please note that we may request additional information from you to verify your identity before we disclose any personal or account information.
- Right to restrict or oppose: where we rely on legitimate interests to process your personal information, you have the right to object to such processing by using the contact information below. Please note that some processing is essential to providing services on the Platform.
- Right to access correct and rectify: you may access, correct and rectify their personal information through their account settings in the Platform.
- Right to delete: you may request deletion of any of your information collected and stored by us please contact us by e-mail at [email protected]
- Revoking consent: For the purposes of European Union data protection legislation, we are the “data controller” of your personal information. You can contact us directly regarding the processing of your personal information by e-mail at [email protected]
Google user data
- The Platform shall not use this Gmail data for serving advertisements;
- The Platform shall not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for the Platform’s internal operations and even then only when the data have been aggregated and de-identified.
Comments and feedback
If you are interested in receiving electronic updates, alerts, and other information from us regarding this Platform, you must provide us with an e-mail address. We may also ask for optional information, such as how you found us, to help us better serve you and other users in the future. We welcome your comments and feedback regarding this Platform and third-party services and functionalities to our e-mail address [email protected] that permits you to send through your own e-mail address, comments, and any other information you choose to include. Please remember that e-mail is not secure and we cannot provide you with any guarantees in this respect. You should carefully consider what information you wish to send to us through e-mail or through this feedback option.