Privacy Policy

OVERVIEW AND SCOPE

INFORMATION WE COLLECT

We collect information about you from a variety of sources, including:

Information we collect directly from you, such as your name, e-mail address.
Information from third parties, such as your Facebook and Instagram username if you “Like” us on Facebook or Instagram.
Information automatically collected, such as the pages you view on our website.

Please note that we may combine information from all of the above sources. If you do not provide information to us, we may not be able to provide our services to (or communicate with) you.

USE OF INFORMATION

We use your information for a variety of purposes, including:

Customer service, such as providing services to you.
Communication, such as responding to your requests for assistance or relevant updates.
Marketing, such as providing you with special offers or deals that we think may interest you.
Administration, such as maintaining our website.
Research and development, such as improving our Site and understanding our customer demographics.
Legal compliance, such as responding to a subpoena or court order.
Protection of us and others, such as investigating a possible crime or enforcing a contract.

SHARING OF INFORMATION

We share your information as follows:

Corporate relatives, such as a corporate subsidiary.
Service providers, such as service providers who host our website.
TCG Site users, such as if you post content on our website or social media and networking platforms that may be available to all visitors.
Unaffiliated third parties, such as social media and networking platforms.
Business transfers, such as if we merge with another legal entity.
In response to legal process, such as in response to a subpoena.
To protect us and others, such as to monitor our website for security issues.
Aggregate and de-identified information, such as aggregate information for statistical analysis.

OTHER IMPORTANT PRIVACY INFORMATION

Cookies and tracking. Our Site uses cookies to improve it and to display a more personalized and relevant experience.
Third-party links. Our Site may contain links to third-party websites and applications; such third-party websites and applications are not governed by this Privacy Notice.
International transfers of information. If you are located anywhere outside of the United States, please be aware that information we collect about you will be transferred to, processed, and stored in the United States
Children. Our Site is intended for general audiences and is not targeted to children.
Security. We have taken steps to help protect the information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, and destruction.
Your California privacy rights. See below for important information for California residents.
Changes to this Privacy Notice. We will post changes to this Privacy Notice on our Site.

YOUR CHOICES

You have certain choices regarding how we use your Personal Information. For example, if you decide you no longer want to receive emails from us, you can let us know by following the unsubscribe link in the email, or by emailing us at

CONTACT US

By email: info@transomcap.com

By mail:
Transom Capital Group
100 N Pacific Coast Hwy
Suite 1725
El Segundo, CA 90245

TCG WEBSITE PRIVACY NOTICE

Welcome to our website for Transom Capital Group and its corporate affiliates (“TCG,” “we,” “us” or “our”). We value our relationship with you, our customer, and your privacy. This TCG Website Privacy Notice explains how and why we collect, use, protect, and share your information, including both Personal Information and Non-Personal Information (defined below), through websites or applications (collectively, the “Site”) where this Privacy Notice is posted.

Each time that you access or use TCG Site, you acknowledge that you have read, understood, and agreed to be bound by this Privacy Notice and the TCG TERMS OF USE. Any dispute over privacy is subject to this Privacy Notice and our TERMS OF USE, including its applicable limitations on damages and the resolution of disputes. Our TERMS OF USE are incorporated by reference into this Privacy Notice. If you do not agree with this Privacy Notice or our TERMS OF USE, you must stop using this Site.

INFORMATION WE COLLECT

The information we collect about you may include both Personal Information and Non-Personal Information. “Personal Information” is information that can identify you as an individual, such as your name, contact information. “Non-Personal Information” is information that does not reveal your individual identity, such aggregate statistics or general demographic information like gender.

We collect information about you from a variety of sources, including:

Information that we collect directly from you includes your name and email address. We will also collect any information that you otherwise provide to us, such as any comments or questions that you submit to us through our Site.
Information that we collect from third parties TCG. If you interact with us on social networking platforms, we may also use that information from those social networking platforms, such as your Facebook username and other publicly available Facebook information.
Information that we automatically collect about you when you use our Site varies depending on the settings of your web browser or device, but it may include the content you view on our Site; the date and time you access our Site; how long you use our Site; the type of web browser you are using (for example, Firefox or Chrome); the type of device you are using (for example, whether you are using a mobile device); and your Internet Protocol address (which is a unique string of numbers to identify devices connected to a network). See the section below titled COOKIES AND TRACKING for more information.

We may combine information from all of the above sources. If you do not provide information to us, we may not be able to provide our services to (or communicate with) you.

USE OF INFORMATION

We use your information for a variety of purposes, including:

Communication. We use your information to communicate with you, including to respond to requests for assistance and updates relevant to you. We may communicate with you in a variety of ways, including postal mail, email, and/or telephone.
Marketing. We use your information for marketing purposes, including to provide you with news, and newsletters; to contact you about products and services we think may interest you; to target advertisements to you; and for other marketing, advertising, and promotional purposes. Our marketing communications with you may include communications via postal mail, email, and/or telephone.
Administration. We use your information for administrative purposes, to help us better understand how our customers access and use our Site; to provide reports to prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect you and us; to enforce this Privacy Notice, our TERMS OF USE, and other policies.
Research and development. We use your information for research and development purposes, including to improve our Site, products, services, and customer experience; to understand our customer demographics; and for other research and analytical purposes.
Legal compliance. We use your information to comply with applicable legal or regulatory obligations, including to respond to a subpoena or court order; to cooperate with law enforcement or other governmental investigations; and as part of legal proceedings.
Protection of us and others. We use your information where we believe it is necessary to protect us and others.

SHARING OF INFORMATION

We share your information with the following entities:

Corporate Relatives. We may share your information with any current or future parent company, affiliate, or subsidiary.
Service Providers. We may share your information with our contractors, vendors, service providers, agents, or others who perform functions on our behalf. For example, we may share your information with service providers who host our Site, coordinate mailings, or analyze aggregate information about our customers.
TCG Unaffiliated Third Parties. We may share the information we collect about you with other unaffiliated third parties, such as social media and networking platforms. These third parties may use such information for their own Direct Marketing Purposes. The use of information by these unaffiliated third parties is governed by the privacy policies of those third parties. See the section titled YOUR CALIFORNIA PRIVACY RIGHTS below for more information about your rights under California law regarding our disclosures to third parties.

We may also share your information in the following ways:

Business Transfers. We may share your information with another entity if we or any of our current or future corporate relatives are acquired by or merged with another legal entity, if substantially all of our assets are sold or transferred to another legal entity, as part of a bankruptcy proceeding, or as part of a similar transfer of assets.
In Response to Legal Process. We may share your information when we believe it is appropriate to comply with the law or a regulatory requirement; to comply with governmental, administrative, or judicial process or other similar requirement or order, such as a subpoena or court order; to cooperate with law enforcement or other governmental investigations (without necessarily requiring the law enforcement or government agency requesting the information to formally serve us with a subpoena); or as evidence in litigation in which we are involved. We also reserve the right to report to appropriate law enforcement or governmental agencies any activities that we believe are in violation of applicable laws, rules, or regulations without providing notice.
To Protect Us and Others. We may share your information where we believe it is necessary to prevent or investigate a possible crime, such as fraud or identity theft; to enforce a contract; to protect the legal rights, Site, or safety of you, TCG, its corporate relatives, and their respective employees, clients, partners, agents, other users, or the public in general; to enforce our TERMS OF USE or this Privacy Notice; and to monitor and remediate security issues.
Aggregate and De-Identified Information. We may disclose aggregate or de-identified information about our customers for marketing, advertising, research, or other purposes

YOUR CHOICES

You have certain choices regarding the Personal Information we collect about you. For example, you may:

Request to Modify the Personal Information We Have Collected About You. You may request to modify your Personal Information by emailing us at info@transomcap.com and specifying the addition, deletion, or other modification to your Personal Information that you would like us to make.
Request to Modify Content You Have Posted. You may request to modify content that you have posted to our Site by emailing us at info@transomcap.com and specifying the content (such as comments or reviews) that you would like modified or deleted. In some cases, we may not be able to remove your content. If this is the case, we will let you know if we are unable to do so and why. Even if we are able to anonymize or make your content or information no longer visible, there is no way to ensure complete or comprehensive removal of your content from the Internet because third parties may have archives of TCG web pages. We therefore cannot prevent such information from being used in a manner that may violate this Privacy Notice, the law, or your personal privacy.
Opt Out of Promotional Email Communications. You may opt out of marketing emails by clicking on the unsubscribe link in the email, or by emailing us at info@transomcap.com . Please also note that if you have previously added your contact information to the mailing list of one of our clients or partners and later withdraw your permission, you will have to contact that third party (or use an opt-out link provided in an email communication from that client or partner) to request removal from that mailing list as well.
Opt Out of Promotional Mail Communications. You may opt out of promotional mail communications by following the instructions provided in the mailing, or by emailing us at info@transomcap.com, and briefly describing the mailing that you would like to unsubscribe from.
Opt Out of Interest-Based Advertising. We may use third-party service providers such as Google’s AdSense and AdWords to help us provide advertisements to you that are tailored to you based on interests that you have expressed on our Site or elsewhere (“Interest-Based Ads”). Any advertisements served by Google, Inc., and affiliated companies may be controlled using cookies. These cookies allow Google to display ads based on your visits to this Site. Any tracking done by Google through cookies and other mechanisms is subject to Google’s own privacy policies. You may decide to disable all the Google cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en. You can use Ads Settings to manage the Google ads you see and opt out of interest-based ads delivered by Google. You also may opt out of receiving Interest-Based Ads from many third-party ad networks, such as those provided by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding Interest-Based Ads by NAI members and DAA members, including how to opt out of Interest-Based Ads provided by NAI and DAA members, please visit their respective websites: www.networkadvertising.org/optout_nonppii.asp (NAI) and www.aboutads.info/choices (DAA). If you are in the European Union, go to www.youronlinechoices.eu for information about your choices with respect to third-party advertising, including instructions on how to opt out of participating ad networks. Please note that opting out of participating ad networks does not mean that you will not see advertisements at all; you will continue to receive advertisements on other websites and from companies that do not participate in the above programs. Even if you opt out of Interest-Based Ads, you may still see ads based on factors such as your general location derived from your IP address, your browser type and recent, previous searches related to your current search.

Please note that even if you opt out of receiving marketing communications from us, we will still respond to your inquiries and requests for information

COOKIES AND TRACKING

We and our service providers use cookies and other mechanisms to track information about your use of our Site. We or our service providers may combine this information with other Personal Information we collect about you.

Cookies. We or our service providers may use cookies to track visitor activity on our Site. A cookie is a text file that a website transfers to your device for record-keeping purposes. We or our service providers may use cookies to track user activities on our Site, such as the web pages you view and time you spend on our Site. The help section on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies may not be able to browse certain areas of the Site.
Clear GIFs, Pixel Tags and Other Technologies. Clear GIFs are tiny graphics with a unique identifier, similar in functionality to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs, pixel tags, or action tags, among other names), in connection with our Site to perform functions like tracking the activities of visitors to our Site, helping us manage content, and compiling statistics about usage of our Site. We or our service providers may also use clear GIFs in emails to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Embedded Scripts. We use embedded scripts, which is code designed to collect information about how visitors interact with a website, such as the website which linked them to our Site.
Third-Party Analytics. We use service providers, such as Google Analytics, to evaluate the use of our Site and our Services. We or our service providers use automated devices and applications to evaluate use of our Site and Services. We or our service providers use these tools to help us improve our Site, Services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or Flash locally shared objects, to perform their services.
Do Not Track. Our Site does not respond to Do Not Track signals. You may disable certain tracking as discussed in this section (e.g., by disabling cookies).

THIRD-PARTY LINKS

Our Site may contain links to non-TCG websites and applications. Any access to and use of such non-TCG websites and applications are not governed by this Privacy Notice. Instead, your use of non-TCG websites or applications is governed by the privacy policies of those third-party websites or applications. We are not responsible for the information practices of such third-party websites and we encourage you to read their privacy policies.

INTERNATIONAL TRANSFERS OF INFORMATION

Our Site is intended to be used by customers located in the United States. If you are located anywhere outside of the United States, please be aware that information we collect about you, including Personal Information, will be transferred to, processed and stored in the United States. The data protection and privacy laws in the United States differ from those of the country in which you are located. U.S. governmental agencies, courts, or law enforcement may be able to access or obtain your Personal Information (for example, in response to a court order).

By using a TCG Site, you consent to the transfer, processing, and storage of your information, including Personal Information, in the United States.

CHILDREN

Our Site is for general audiences and is not targeted to children under thirteen (13) years of age. We do not knowingly collect any Personal Information from children younger than the age of thirteen (13), and we will delete any Personal Information collected that we later know to be from a customer under the age of thirteen (13). If you believe a child under the age of thirteen (13) has disclosed Personal Information to us, please contact us at info@transomcap.com and specify the customer and information you believe to be from the child under thirteen (13).

SECURITY

We have taken steps to help protect the information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. Please note that we cannot guarantee the security of any information we have collected about you, and your use of our Site indicates that you understand and accept this risk

YOUR CALIFORNIA PRIVACY RIGHTS

In June 2018, California enacted the California Consumer Privacy Act (“CCPA”), which went into effect January 1, 2020. The CCPA was designed to enhance privacy rights and consumer protection for California residents by granting new rights to California consumers and new obligations upon companies doing business in California with regarding to personal information. The CCPA broadly defines “personal information,” which includes at least the following categories:

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
Any information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Characteristics of protected classifications under California or federal law.
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Biometric information.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
Geolocation data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information.
Education information.
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

For more information regarding your rights under the CCPA, please visit https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375 for the text of the Act or https://oag.ca.gov/privacy/ccpa for information from the California Attorney General.

Under the CCPA, the new rights granted to California consumers are as follows:

Right to Access and Disclosure of Personal Information Collected. Consumers have the right to request that a business disclose what personal information the business has collected about the consumer, how it is used and whether the information has been sold or shared with third parties. Consumers also have the right to access the personal information that has been collected about them. A business must provide the information free of charge and in a readily useable format within 45 days of receiving a Verifiable Consumer Request (“VCR”).
TCG has listed above the categories of information it collects and how it uses that information. If you are a California resident and would like to make a VCR for specific personal information collected by TCG, please contact us at (424) 293-2818(424) 293-2818 or info@transomcap.com and include “CCPA VCR” in the Subject line of the e-mail. Please include your name, contact information, and a detailed description of the information you are requesting.
Right to Request Deletion of Personal Information Collected. Consumers have the right to request that a business delete personal information that has been collected from the consumer.
If you are a California resident and would like to make a VCR for the deletion of specific personal information collected by TCG, please contact us at (424) 293-2818 or info@transomcap.com and include “CCPA VCR” in the Subject line of the e-mail. Please include your name, contact information, and a detailed description of the information you are requesting to be deleted.
Right to Opt Out of the Sale of Personal Information. Consumers have the right to opt out of the sale of their personal information by a business to third parties.
We do not sell contact information to anyone nor intend to do so.
(424) 293-28184. Right to Nondiscrimination. Consumers have the right not to be treated differently in terms or price or service because they have exercised their rights under the CCPA.
TCG is committed to treating all consumers equally, regardless of their exercise of any of their rights under the CCPA. If you have any questions or concerns regarding our nondiscrimination policy, please contact us at (424) 293-2818 or info@transomcap.com.

CHANGES TO THIS PRIVACY NOTICE

This Privacy Notice will be updated from time to time. Changes to this Privacy Notice will go into effect when posted. If revisions to this Privacy Notice materially affect how we use Personal information that we collected from you prior to the date of the revised Privacy Notice, we will obtain your consent for any new uses or sharing of your Personal Information. We will post any updated Privacy Notice to our Site.

CONTACT

By email: info@transomcap.com

By mail: Transom Capital Group
100 N Pacific Coast Hwy
Suite 1725
El Segundo, CA 90245