PRIVACY POLICY

General

This Privacy Policy describes how Total Communications, Inc. (collectively, “TotalComm,” “we,” “us,” or “our”) collects, uses and shares personal data collected from visitors to our website and in connection with our information technology consulting services (collectively, our “Services”).  

By using any of our Services, you are agreeing to the terms of this Privacy Policy. If you are a California resident, please see our California Consumer Privacy Act Disclosure below.

This Privacy Policy does not apply to the extent that we process any personal data in the role of a processor or service provider on behalf of our customers. In such circumstances, our customers are responsible for the information they ask us to process as well as compliance with applicable laws and regulations. When you interact with one of our customers, such as through their website, you are subject to their privacy policies and terms of use.

Types of Information We Collect and How We May Share Your Information 

When you interact with one of our Services, we may collect certain information about you. Please see the chart below to understand what information we collect, the sources of that information, how and why we will use that information, and the potential other recipients of that information. 

Category of Personal Information Collected

Source of Information

Purpose for Collection

Categories of Recipients

“Identifying Information,” such as your name, mailing address, email address, and telephone number.

We may collect Identifying Information from you when you visit and use our Services and communicate with us (including on one of our social media accounts).


We may also receive information about you from third party sources. 

We use Identifying Information to fulfill your orders for our services, to answer your communications, to market our services to you, to notify you of any issues with our services, to consider you for employment when you apply for a job, and to improve our website and services. 



We may share Identifying Information with applicable third-party service providers who support our business, such as, professional advisors as well as web-hosting providers, analytics providers, customer-relationship management software providers and other information technology providers.  

“Order and Payment  Information,” such as your purchase history, support history, billing addresses, and credit and debit card number.

We may collect Order and Payment Information when you make a purchase of our Services or otherwise interact with our Services. 

We use Order and Payment Information to fulfill your orders for services, to answer your communications and for analytic and marketing purposes to improve our website, products and services. 

We may share Order and Payment Information with our third-party service providers (see list above).   

Please note that payment card information is transmitted via encrypted transmission solely to our payment card processor and is not retained by TotalComm.  

“Professional and Employment Information,” such as your educational and professional history.

We may receive this information when you voluntarily provide it, such as when you submit a resume to TotalComm or when you provide us information about your employer.

To consider your application for employment or to provide Services to your employer.

We may share Professional and Employment Information with our third-party service providers.  

“Device Information,” related to your interactions with us, such as device information, browser type and operating system, Internet Protocol (IP) address (a unique number that identifies your internet access), cookie information, pages viewed and accessed (including those viewed before and after interacting with our Services), how long you accessed our Services and other technology in any given session, and the date and time of access. 

We may collect Device Information automatically when you visit our Services or otherwise interact with us. See below for more information on cookies and other technologies used by us.

We use Device Information to ensure that our Services work properly, for analytics and marketing purposes, and to evaluate whether our Services are secure.  

We may share Device Information with our third-party service providers.  

 

TotalComm may also receive other, additional categories of personal information that you voluntarily provide when you interact with our Services.  For example, if you 

  • Subscribe to our newsletters, programs, promotional emails or other materials or participate in a promotion;
  • Apply for a job, submit your resume/CV or create a candidate profile; 
  • Communicate with our customer service representatives; or 
  • Contact us with your questions/comments.

This information is all collected when you voluntarily provide it.  

Please note that we may also use and disclose any information collected through our Services to: (i) comply with our legal and regulatory responsibilities and to enforce our rights; (ii) authenticate users and to provide for the safety and security of our Services and otherwise prevent fraud and other prohibited or illegal activities; (iii) protect the security of our Services, our businesses and our products; (iv) to our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business; or (v) otherwise as disclosed to you at the point of collection.

Except as otherwise provided in this Privacy Policy, we will not disclose your personal information to third parties for their own marketing purposes without your consent.

Choices Regarding Our Collection and Use of Your Information

We may offer you choices regarding the information we collect and how that information is used and shared. These choices may include the ability to access, update or delete information that you have provided to us or information that we have collected through your use of our Services. They may also include the ability to opt-out of receiving notifications, promotions, offers or other advertising from us. To inquire about making any of these requests please contact privacy@totalcomm.com.

If you are a resident of California, you have specific rights in relation to your personal information. Please review the section California Consumer Privacy Act Disclosure below for more information.

Users Outside the United States

TotalComm is located in the United States. Our Services are directed solely towards users who reside in the United States. If you choose to use our Services from outside the United States, you are consenting to the collection, storage, processing, and transfer of your information in and to the United States, pursuant to the laws of the United States.

How We Secure Your Personal Information

We will take reasonable steps to protect your personal information as you transmit your information from your computer to our Services and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction. For example, we use a third-party vendor to process credit card transactions. Our online payment site along with our processing partner reside on secure web servers that encrypt the data between the customer and the processing vendor. By using this service, we do not collect any credit or debit card numbers or store such information. You should keep in mind that no Internet transmission is ever 100% secure or error-free. In particular, email sent to or from our Services may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. 

Links to Other Web Sites

You should be aware that when you are on our Services you could be directed to other sites beyond our control. These other websites may send their own cookies to you, independently collect data or solicit personal information and may or may not have their own published privacy policies. If you visit a website that is linked to one of our Services, you should consult that site’s privacy policy before providing any personal information. Please note that we are not responsible for the privacy practices of third parties, including those of our customers as described above.  

Collection and Use of Children’s Personal Information

TotalComm takes children’s privacy seriously, although our services are not directed at children. If we become aware that personal information from a child under 18 has been collected without such child’s parent or guardian’s consent, we will use all reasonable efforts to delete such information from our database. If any parent, guardian or other responsible adult becomes aware that we have collected personal information from a child under the age of 18, please contact us at privacy@totalcomm.com.

How We Use Cookies and Other Tracking Technologies

Our website uses a standard technology called a “cookie” and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our website. These technologies automatically identify your device whenever you interact with our website.  

Categories of Cookies

We may use cookies for the following types of purposes:  

Strictly necessary cookies. These are cookies that are required for the operation of our website. 

Performance cookies.  These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around and interact with our website. If you do not allow these cookies we will not know when you have visited our website and will not be able to monitor its performance.

Functional cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you and remember your preferences.

Targeting cookies. These cookies may be set through our website by our marketing partners. They may be used by those companies to build a profile of your interests and show you relevant advertisements on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and device. If you do not allow these cookies, you will experience less targeted advertising.

You can find more information about the individual cookies we use and the purposes for which we use them in the tables below:

Strictly Necessary Cookies

Organization

Cookie

Type/

Retention Period

Description

TotalComm

__cf_bm

Session


30 minutes

We use CloudFlare cookies to help protect and operate our website.  In particular, the __cf_bm cookie is a cookie necessary to support Cloudflare Bot Management. 

Performance Cookies

Organization

Cookie

Type/ 

Retention Period

Description

HubSpot

__cf_bm




30 minutes

HubSpot is a web analytics service that we use to keep track of users when using our Services.  For example, it allows to track a user’s identity across different pages of our site.  


For HubSpot’s privacy policy, please see: 

https://legal.hubspot.com/privacy-policy





Functional Cookies

We do not use any functional cookies at this time. 

Targeting Cookies

We do not use any targeting cookies at this time.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from our website you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It’s also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser’s “Help” function or alternatively, you can visit http://www.aboutcookies.org,  which explains, step-by-step, how to control and delete cookies in most browsers.

Similar Technologies

We use technologies that resemble cookies to help track user activities and preferences. For example, we may use web beacons (tiny graphics with a unique identifier embedded on web pages or emails) to track your activities and communicate with cookies. You cannot opt out of web beacons used on webpages, but you can limit their use by opting out of the cookies they interact with. You can opt out of web beacons used in emails by setting your email client to render emails in text mode only.

Do-Not-Track

Some browsers have incorporated a Do-Not-Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our Services.  

Social Media Features

Our Services may include social media features, including the Facebook “Like” button, the LinkedIn “follow” button, and the Instagram “Follow” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing it.

Changes to This Privacy Statement

We will occasionally update this Privacy Policy. If we make changes to this Privacy Policy or make any material changes to how we use your personal information, we will revise this Privacy Policy to reflect such changes and revise this Privacy Policy’s effective date, included at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we are using and protecting your personal information.

Other Terms

Your use of our Services is subject to the Terms of Use. If you choose to use our Services, your visit and any dispute over privacy and data collection is subject to this Privacy Policy and the Terms of Use, including limitations on damages, dispute resolution procedures and application of the law of the State of Connecticut.

Contacting Us

If you would like to contact us for any reason regarding our privacy practices, please write to us at the following address:

Total Communications, Inc.
Attention: Privacy Officer
333 Burnham Street 

East Hartford, CT 06108
privacy@totalcomm.com

California Consumer Privacy Act Disclosure

This California Consumer Privacy Act Disclosure describes how Total Communications, Inc. (“TotalComm,” “we,” “us,” or “our”) collects, uses and discloses personal information relating to California residents (consumers) covered by the California Consumer Privacy Act of 2018, as amended (“CCPA”).

Introduction

Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident. The specific Personal Information that we collect, use, and disclose relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. For more information about how we collect, disclose, and secure information, please refer to our general Privacy Policy above. Terms that are used, but not defined, in this CCPA Disclosure are defined in the CCPA.

Collection and Disclosure of Personal Information

In the past 12 months, we have collected, and disclosed to third parties for our business purposes, the following categories of Personal Information relating to California residents covered by this disclosure:

Category 

Examples 

Collected 

A. Identifiers. 

A real name, alias/nickname, postal address, email address, account name, telephone number, Social Security number, driver's license number, passport number, Internet Protocol address, online identifier, photographs or other similar identifiers. 

YES 

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). 

A 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. Some personal information included in this category may overlap with other categories.  

YES 

C. Protected classification characteristics under California or federal law. 

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation and veteran or military status.   

YES 

D. Commercial information. 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. 

YES 

E. Biometric information. 

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. 

NO 

F. Internet or other similar network activity. 

Browsing history, search history, information on interactions with a website, application, or advertisement.  

YES 

G. Geolocation data. 

Physical location or movements.  For example, GPS tracking on Company vehicles.

NO 

H. Sensory data. 

Audio, electronic, visual, thermal, olfactory, or similar information.  

NO 

I. Professional or employment-related information. 

Current or past job history or performance evaluations, licenses, seniority, training, employment start and ending dates, job titles, and professional memberships and affiliations. In addition, we collect educational information, such as institutions attended, degrees attained and transcripts.  This category may also include salary, bonus and commission, hours and overtime, benefits and leave information.  

YES 

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. 

NO 

K. Inferences drawn from other personal information. 

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. 

NO 

L. Sensitive Personal Information. 

Social Security Number, driver’s license, account credentials, financial information (such as bank account and number information for direct deposits), precise geolocation, race or ethnic origin, religious beliefs, contents of messages, genetic data, biometric information.   

NO 

 

We do “sell” or “share for consideration” consumer personal information under the CCPA. To provide our Services, we might share information with our service providers. For example, we provide our Services in part by storing information with our cloud storage providers. These service providers are bound by contract to perform only the services requested, and prevented from using the information for their own purposes or sharing it any further. Because we do not sell or share personal information, as defined by CCPA, it's not necessary for you to opt out of the sale of your personal information. 

The categories of sources from whom we may have collected this Personal Information are:

  • Directly from a California resident or the individual’s representatives;
  • Service Providers, Consumer Data Resellers and other third parties;
  • Public Record Sources (Federal, State or Local Government Sources); and
  • Website/Mobile App Activity/Social Media.

The categories of third parties to whom we may disclose Personal Information for our business purposes described in this privacy disclosure are:

  • Service Providers who support our business, such as professional advisors as well as web-hosting providers, analytics providers, customer-relationship management software providers and other information technology providers;
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals’ personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues; and
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

Use of Personal Information

In the past 12 months, we may have used Personal Information relating to California residents to:

  • Deliver the services and support or carry out the transactions for our Services that you have requested;
  • Send communications to you, such as to respond to your requests and to provide you Services and related support; 
  • Customize, analyze and improve our products, services (including the content and advertisements on our website), technologies, communications and relationship with you;
  • Comply with our legal and regulatory responsibilities and to enforce our rights;
  • Authenticate users and to otherwise provide for the safety and security of our Services and otherwise prevent fraud and other prohibited or illegal activities;
  • Protect the security of our website(s), our business(es), or our products or services; or
  • Otherwise, as disclosed to you at the point of collection.

Rights under the CCPA

If you are a California resident, you have the right to:

  1. Request we disclose to you free of charge the following information covering the 12 months preceding your request:
    1. the categories of Personal Information about you that we collected;
    2. the categories of sources from which the Personal Information was collected;
    3. the purpose for collecting Personal Information about you;
    4. the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
    5. the specific pieces of Personal Information we collected about you;
  2. Request we delete Personal Information we collected from you, unless the CCPA recognizes an exception; 
  3. Opt-out of our sale or sharing of your personal information (which we do not currently do – see above); and
  4. Be free from unlawful discrimination for exercising your rights under the CCPA.

We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. Requests for specific pieces of Personal Information will require additional information to verify your identity. If you submit a request on behalf of another person, we may require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

In some instances, we may not be able to honor your request, and we will advise you of that fact in our response. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer or where the Personal Information that we maintain about you is not subject to the CCPA’s access or deletion rights.

How to Exercise Your Rights

If you are a California resident, you may submit a request by emailing your request to privacy@totalcomm.com.