Last Updated: January 2025

T.K. Keith Company, Inc. doing business as Thrive Payments (“TKKC”, “we”, “us”, or “our”) is a privately held Massachusetts corporation located at 500 Edgewater Drive, Suite 516, Wakefield, Massachusetts.

Purpose of this Privacy Policy

TKKC has established this privacy policy (“Privacy Policy”) to inform you of the privacy practices relative to the collection of personal information, information security, and privacy standards applicable to all users of our websites, which includes thrivepay.us and any applications or gateways that may be utilized by you (“Websites”) and payment processing and merchant services function (“Services”). By visiting our Websites and utilizing our Services, you are accepting the practices described in this Privacy Policy. All information collected by TKKC is used for the purposes of providing the Services, providing support to customers/clients for agreed upon Services, and to improve and expand upon our current catalog of Services. If you are a TKKC customer, the terms of our contractual agreement with you may contain more specific provisions relating to data use and data privacy. If you have received a separate privacy notice or signed a contractual agreement containing more specific data privacy or data use terms, in means that the terms of that notice or agreement will govern our processing of your personal information with respect only to the relevant Service. If you have not received a separate notice or signed a contractual agreement containing more specific data privacy or data use terms, it means that our collection and processing of your personal information in connection with the relevant Service will be consistent with this Privacy Policy. The Privacy Policy will notify you of the following:

1. What personally identifiable information is collected from you through the Websites and our Services, how it is used and with whom it may be shared.
2. What choices are available to you regarding the use of your data.
3. The security procedures in place to protect the misuse of your information.
4. How you can correct any inaccuracies in the information.

Information Collection, Use, and Sharing

TKKC is the sole owner of the information collected on thrivepay.us. TKKC only has access to/collects information that you voluntarily give us via email, the contact submission form, or any other direct contact from you. We may also collect information about you from business partners, service providers, co-marketers, and other third parties. For example, we may receive referrals from financial institutions or other partners with which you have a relationship. We may also receive business-related information about you from third-party companies that supplement our business customer records with, for example, professional information or other information collected through technology when you visit our Website or interact with an email we send you -please see the “Cookies and Web Analytics” section below for more information.  In addition, when you visit our Websites, we may collect certain information about your location, usage, or device through technology such as cookies (see “Cookie Settings” on the Website banner to adjust your permissions).  TKKC will not sell or rent this information to anyone.

In the provision of merchant services, TKKC has access to confidential and proprietary information, which includes but is not limited consumer personal and business information and, in some cases, cardholder data (“Personal Information”). Personal Information includes personal information of a consumer, including but not limited to names, addresses, telephone numbers, account numbers, employment information, credit information, personal data, demographic, financial and transaction information, numbers or copies of government-issued identification such as Social Security Numbers, Tax Identification Numbers, Passport Numbers, state or local identification numbers such as a Driver’s License, and non-public information of a commercial client, including but not limited to financial information, pricing and customer lists, which TKKC and its affiliates may receive from a client, or from sources on the client’s behalf, in the course of and solely for the purposes of TKKC’s provision of Services to the client.

TKKC limits use of Personal Information solely for the purposes of performing contractual Services to its clients and does not disclose Personal Information to third parties, except as directed by a client or to the extent that disclosure of any such information is necessary to facilitate TKKC’s provision of Services. TKKC may provide some Personal Information to our business partners, service providers, co-marketers, and other third parties; however, we will never sell or rent your Personal Information as part of a customer list or similar transaction for unrelated parties to independently market to you. We provide products and services to customers through a number of business partners and third-party vendors. To the extent permitted under applicable laws, we may share your Personal Information with our business partners, service providers, or other third parties that enable us to serve your processing needs. We may contact our existing customers by mail, telephone, or email to offer additional products or services that we believe may be of interest to you. Although our treatment of your Personal Information is governed by this Privacy Policy, the business partner, service provider, or other third party’s treatment of your Personal Information will be governed by the business partner or third party’s privacy policy.

We may also use or disclose Personal Information if required to do so by law or in the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Website; (b) protect and defend our rights or property, the Website or our users, or (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents, or the users of the Website or the public.

To the extent permitted under applicable laws, we may disclose or share anonymous information (or other information, other than Personal Information) in any other manner that we deem appropriate or necessary. For the avoidance of doubt, “anonymous information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, a particular individual or business. In the event anonymous data is combined with other identifying information, we will treat it as Personal Information. 

TKKC may use your information in the following ways: 

1. To respond to you, regarding the reason you contacted us. TKKC will not share your information with any third party outside of our organization, other than as necessary to fulfill your request, e.g. to ship an order;
2. To operate, maintain, and improve the Services and features of the Websites, as applicable;
3. Disclosure to service providers and contractors who help manage, develop, and analyze our business and/or deliver services to us and our clients with respect to the Services;
4. To report to credit bureaus consistent with a legitimate business purpose associated with the Services;
5. From time to time we may share information collected from you, including Personal Information, as defined herein, with our agents, representatives, contractors, professional advisors, and service providers so they may assist TKKC with various support services including, but not limited to, marketing and payment processing;
6. We may also share information collected from you, including Personal Information, with third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) to protect the security or integrity of our Services; and/or (iii) to exercise or protect the rights, property, or personal safety of TKKC, its users, or others;
7. We may use your e-mail address to send commercial or marketing messages regarding specials, new products, and/or services and you may opt-out of receiving such communications from us at any time by using the unsubscribe link provided on email messages we may send. 
8. We may also use your email address for non-marketing or administrative purposes (such as notifying you of major Website changes, updates to this Privacy Policy, and/or for customer service purposes) or providing customer support.  Your email address may also be required to enable some of Services offered on or through our Websites. As always, you may opt-out of receiving these communications from us at any time by using the unsubscribe link provided on email messages we send; however, be advised that you may limit and/or interfere with our ability to relay relevant information to you;
9. To improve the quality and design of our Websites, improve our Services, create additional features and functionalities, personalize content, diagnose technical problems, track visitors and Website traffic by analyzing user preferences, trends, and activity. For more information, please see the Cookies section below and/or the Cookies Settings banner at the bottom of our Website;
10. Any financial information that is collected will be used to process charges associated with your use of the Services;
11. TKKC may sell or transfer some or all of its business or assets, including Personal Information, in connection with a business transaction (or potential business transaction) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Policy; however, we cannot many any promise or guarantee;

Your Access to and Control Over Information

You may opt out of any future contacts from us at any time. To the extent required by law, we provide you with (i) reasonable access to your personal information collected through our Services, if any, and (ii) the ability to take the following actions at any time by contacting us via the email address or phone number given on our Websites:

• Change/correct any data TKKC has about you.
• Have us delete any data TKKC has about you.
• Express any concern you have about TKKC’s use of your data.

When we rely on your consent as the legal basis for our processing of personal information, you may withdraw your consent as may be instructed on the Website or other communications, or by contacting us using the information in the “Contact Us” section or the “Unsubscribe” section of our Website.

Subject to your consent if required by applicable law, we may use personal information to provide you with direct marketing information about our Services as well as those of third parties. Our direct marketing may occur through email, telephone, post or SMS or such other method(s) as may become relevant.

We will take steps to seek to ensure that any direct marketing from us and which is sent by electronic means will provide a simple means for you to stop further communications, in accordance with applicable law. For example, in emails, we may provide you with an “unsubscribe” link, or an email address to which you can send an opt-out request. In addition, if we need your consent for direct marketing communications under applicable law, and if you provide your consent, you will be able to change your mind at any time. Please note that if you opt out of receiving marketing-related communications from us, we may still send you administrative, transactional, or information messages, from which you cannot opt out.

Security

TKKC uses Personal Information to perform certain merchant acquiring services in compliance with applicable law, the privacy rules and regulations of the card networks, and the Payment Card Industry Data Security Standard (PCI DSS). TKKC has adopted and implemented an information security program with appropriate controls and measures, including the establishment and maintenance of policies, procedures and technical, physical and administrative safeguards, designed to restrict access to and otherwise protect the security and confidentiality of Personal Information. TKKC maintains appropriate safeguards to protect against reasonably foreseeable internal and external risks to the security, confidentiality and integrity of Personal Information that could result in the unauthorized access to, disclosure of or misuse, alteration, destruction or other compromise of Personal Information.

When you submit sensitive information to us in the course of visiting our Websites or utilizing the Services, your information is protected both online and offline. Wherever TKKC collects sensitive information, that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a closed lock icon at the bottom of your web browser, or looking for “https” at the beginning of the address of the web page.

While TKKC uses encryption to protect sensitive information transmitted online, TKKC also protects your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers and/or any cloud-based environment in which TKKC store personally identifiable information are kept secure.

Despite our extensive efforts to protect your Personal Information, no method of transmission over the internet, or method of electronic storage is 100% secure or error free, thus, TKKC cannot guarantee its absolute security. We expressly disclaim any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your information, including, without limitation, Personal Information or usage information through the Website or our use of our Services. You play an important role in keeping your information secure. You should not share your username, password, or other security information for your account with anyone. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us as detailed in the ‘Contact Us’ section.

Retention Period

We only store information for as long as is needed to fulfill our contractual or legal obligations or any other permissible purpose for which we have collected it and to satisfy any other legal record retention requirements. The criteria used to determine our retention periods include, without limitation:

• The length of time we have an ongoing relationship with you and provide Services to you, for example, for as long as you have an account with us or continue to use our Services, and the length of time thereafter during which we may have a legitimate need to reference personal information to address issues that may arise;
• Whether there is a contractual obligation to which we are subject, for example, our contracts with our customers may specify a certain period of time during which we are required to maintain the information on behalf of our customers;
• Whether there is a legal obligation to which we are subject, for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them; and
• Whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations.

Links and Third Parties

The Websites may contain links to other sites. Please be aware that TKKC is not responsible for the content or privacy practices of such other sites. TKKC encourages our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. By engaging with third party websites through our Websites, you consent to our providing your Personal Information to those third parties. Data collected by the third-party websites (even if offered on or through our Website) may not be received by us. As such, we have no responsibility or liability for the independent policies or actions of third parties, and are not responsible for the privacy practices or the content of any such website or services. These linked sites, services and tools are only for your convenience, and you therefore access them at your own risk. The third-party’s terms of service, privacy policy, permissions, notices, and choices should be reviewed regarding their collection, storage, and sharing practices prior to providing any information to or through them.

Cookies and Web Analytics 

We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services. These third parties may use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our Services, webpages viewed, time spent on webpages, and links clicked. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser to make the site more user friendly, enhance your experience, and customize the content, and/or alert your to new items of interest. “Web beacons” are small image files that are loaded when a web page or other online resource is processed by your browser (including when emails are opened). If you click on one of our ads on another party’s website, cookies may also be used to track the effectiveness of our online advertising and for the purposes of delivering ads that may be relevant to you in the future. Our Websites use cookies including cookies that are strictly necessary to enable the features of our site, performance cookies to see how visitors use our site, and functionality cookies that enable the site to “remember” machines or devices, personalize website content and tailor user experience. Additional information about the types of cookies we may use and how to opt out of the sharing of such cookie data is provided in the Cookies Settings banner at the bottom of our Website. This Privacy Policy does not cover the use of cookies, web beacons, or other tracking technologies by any advertisers or third parties.

Children

Our Services are not intended for use by children. We do not solicit or knowingly accept any Personal Information from persons under the age of 18. Please do not visit our Websites or use our Services if you are under the age of 18.

Users Outside the United States

If you are located outside the United States of America, you should be aware that your Personal Information will be transferred to the United States of America, the laws of which may differ from the laws of your country. If you are located in a country outside the United States of America and voluntarily submit Personal Information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage or processing of that information in, the United States of America and you understand that your information may be available to government authorities under lawful orders and laws applicable there. We may store and process your Personal Information in any country where we have facilities (which currently is only in the United States) or in which we engage service providers, and, by using the Services, you consent to the transfer of Personal Information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

Choice of Law

The Websites are intended for use in the United States of America and you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the Commonwealth of Massachusetts and the courts of the Commonwealth of Massachusetts shall have exclusive jurisdiction to resolve any such disputes. In the event the choice of law differs from an agreement you may have with us for any Services, the law expressly outlined in any such agreement shall control. You also agree to abide by any limitation on damages contained in any agreement that we may have with you. We attempt to protect the Personal Information of all users of the Websites and we attempt to comply with local data protection and consumer rights laws to the extent they may apply to the TKKC Services, but the Websites are targeted to United States of America citizens and our policies are directed at compliance with those laws. If you are uncertain whether this Privacy Policy conflicts with the applicable local privacy laws where you are located, you should not submit your Personal Information to TKKC.

Region-Specific Information

We may choose or be required by law to provide different or additional disclosures or rights relating to the processing of Personal Information about residents of certain countries, regions or states. If you believe you are subject to these different or additional disclosures or rights, please contact us via the ‘Contact Us’ section of our Website. 

Commonwealth of Virginia, Colorado, or Connecticut

Privacy regulations of the Commonwealth of Virginia Colorado, or Connecticut only apply to the residents of such states/commonwealths acting in an individual or household capacity and does not apply to the data of Colorado, Connecticut, or Virginia residents acting in a commercial or employment context. It also does not apply to the extent data is handled pursuant to the Gramm Leach Bliley Act (“GLBA”). We describe the categories of personal data that we process and disclose to third parties, the purposes for which we process personal data, and the categories of third parties that we disclose personal data to in the relevant sections above. If you are a resident of these states/commonwealths and have any specific questions regarding how we may utilize or share your Personal Information, or wish to change how we may utilize or share your Personal Information, please contact us via the ‘Contact Us’ section of our Website.

Updates & Contacting Us

We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this Privacy Policy, in whole or in part, at any time. When we amend this Privacy Policy, we will revise the “Last Updated” date located at the top of the document. If you provide personal information to us or access or use our Services after this Privacy Policy has been changed, you will be deemed to have unconditionally consented and agreed to such changes. The most current version of this Privacy Policy will be available on this page and will supersede all previous versions of this Privacy Policy. 

If you feel that TKKC is not abiding by this Privacy Policy, you should contact us immediately via the ‘Contact Us’ section of our Website or by phone at: 855.794.2602.

Special Privacy Notice for California Residents

The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (together, with related regulations, the “CCPA”).

California residents (“you”) have the right to be informed of the categories and specific pieces of personal information (including sensitive personal information) collected, used, and disclosed, the categories of sources from which that information is collected, whether that information is sold or shared, the categories of third parties to whom that information has been disclosed, the business or commercial purposes for collecting and using each category of personal information, and the intended retention period for each category of personal information.

The chart below reflects the categories of personal information we have collected from California residents during the past twelve months, the categories of sources from which the information was collected, the business or commercial purpose for which the information was collected, the categories of third parties to whom we disclosed that information, and our anticipated retention period for each category of information.

Categories of Personal Information	Sources of Collection	Business or Commercial Purpose for Collection	Categories of Third Parties Receiving Personal Information	Retention Period
Identifiers This may include: name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Directly from you; your devices, operating system, browser, or activity within our Services; vendors that assist us in providing our Services and running our internal business operations; data analytics providers; advertising networks; public databases; social media platforms; other data providers. For job applicants: Recruiters; background check providers	Fulfill or meet the reason you provided the information; provide our Services to you, including verifying your information, billing and processing payments, analyzing data, marketing, selling advertising, and similar functions and services; communicate with you; protect and secure our environment; verify, maintain, improve, upgrade, or enhance our Services; identify and repair errors; satisfy our legal obligations; market to you. For job applicants: Process and assess your application.	Customer relationship management providers; data analytics providers; credit and collection agencies; marketing service companies. For job applicants: Background check providers; human resource providers; technology providers and technology support services.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us, or for the length of time necessary to fulfill our business purposes, whichever is longer.
California Customer Records Information (per Cal. Civ. Code § 1798.80(e)) This may include: name, signature, social security number, physical characteristics or description, address, telephone number, government issued ID numbers, education, employment, employment history, credit or debit card number or other financial information, or medical or health insurance information.	Directly from you. For job applicants: Recruiters; background check providers.	Provide our Services, including verifying your information, billing and processing payments, analyzing data, marketing, selling advertising, and similar functions and services; communicate with you; improve, upgrade, and enhance our Services; detect security incidents and protect against fraud or illegal activity; process and manage interactions and transactions for our Services; satisfy our legal obligations. For job applicants: Process and assess your application.	Customer relationship management providers; data analytics providers; credit reporting agencies; marketing service companies. For job applicants: Human resource providers; technology providers and technology support services.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Protected classification characteristics under California or federal law This may include: age, veteran status, accommodations information, gender identity and expression, sexual orientation, and religion.	Directly from you. For job applicants: Recruiters; background check providers.	Provide our Services, including verifying your information, billing and processing payments, analyzing data, marketing, selling advertising, and similar functions and services; improve, upgrade, and enhance our Services, including reasonable accommodations For job applicants: Process and assess your application.	Customer relationship management providers; advertising networks, marketing service companies, verification providers, data analytics providers. For job applicants: Human resource providers; technology providers and technology support services.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Commercial information This may include: records of real property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	You; Third-party sources	Provide our Services, including verifying your information, billing and processing payments, analyzing data, marketing, selling advertising, and similar functions and services; improve, upgrade, and enhance our Services, including via internal research and development; satisfy our legal obligations; market to you.	Customer relationship management providers; data analytics providers; verification providers, marketing service companies. For job applicants: Human resource providers; technology providers and technology support services.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Internet or other electronic network activity information This may include: browsing history, search history, information on interactions with our Website, application, advertisement, or Services.	Directly from you; your devices, operating system, browser, or activity within our Services; vendors that assist us in providing our Services and running our internal business operations; data analytics providers; advertising networks; public databases; social media platforms; other data providers.	Provide our Services, including verifying your information, billing and processing payments, analyzing data, marketing, selling advertising, and similar functions and services; monitor and improve our Services, including via internal research and development; detect security incidents and protect against fraud or illegal activity.	Customer relationship management providers; data analytics providers; technology providers, advertising networks; marketing service companies. For job applicants: Human resource providers; technology providers and technology support services; video hosting, sharing, and services platforms; webinar software platforms.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Geolocation data This may include: physical location or movements, or location data obtained from your IP address.	Directly from you; your devices, operating system, browser, or activity within our Services; vendors that assist us in providing our Services and running our internal business operations; data analytics providers; advertising networks; public databases; social media platforms; other data providers.	Provide our Services, including verifying your information, billing and processing payments, analyzing data, marketing, selling advertising, and similar functions and services; monitor and improve our Services.	Customer relationship management providers; data analytics providers; marketing service companies. For job applicants: Human resource providers; technology providers and technology support services; video hosting, sharing, and services platforms; webinar software platforms; payroll and benefit providers.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Sensory data This may include: audio recordings, electronic, visual, or similar information.	Directly from you.		Customer relationship management providers; call center providers; marketing service companies. For job applicants: Human resource providers; technology providers and technology support services; video hosting, sharing, and services platforms; webinar software platforms; payroll and benefit providers.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Professional or employment information This may include: current and prior employment, performance evaluations, and results of background checks.	Directly from you. For job applicants: Recruiters; background check providers.	Provide our Services, including verifying your information, billing and processing payments, analyzing data, marketing, selling advertising, and similar functions and services; protect and secure our environment, including against malicious, deceptive, or illegal activity. For job applicants: Process and assess your application.	Data analytics providers, marketing service companies. For job applicants: Background check providers; human resource providers; technology providers and technology support services; payroll and benefit providers.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Educational Information This may include: degrees or other professional credentials	For job applicants: Directly from you; recruiters; background check providers.	For job applicants: Process and assess your application.	For job applicants: Background check providers; human resource providers.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Inferences drawn from other Personal Information This may include: creating a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitude, intelligence, abilities, and aptitudes.	Directly from you; your devices, operating system, browser, or activity within our Services; vendors that assist us in providing our Services and running our internal business operations; data analytics providers; advertising networks; public databases; social media platforms; other data providers.	Analyzing data, marketing, selling advertising, and similar functions and services; monitor and improve our Services, including via internal research and development.	Data analytics providers, marketing service companies.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.

	Sensitive Personal Information Category as set forth in Cal. Civ. Code § 1798.140	Sources of Collection	Business or Commercial Purpose for Collection	Categories of Third Parties Receiving Personal Information	Retention Period
	Social security number, driver’s license number, state identification card, or passport number.	Directly from you. For job applicants: Recruiters; background check providers.	To satisfy legal obligations. For job applicants: Process and assess your application.	Background check providers; human resources software providers; payroll and benefit providers; technology providers and technology support services.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer. Barring any legally required additional retention period, up to three years for non-hired applicants.
Citizenship or Immigration Information		Directly from you. For job applicants: Recruiters; background check providers.	To satisfy legal obligations; fulfill or meet the reason you provided the information; provide you with our Services;. For job applicants: Process and assess your application.	Background check providers; human resources software providers; payroll and benefit providers; verification providers, technology providers and technology support services.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Account access credentials (user names, account numbers, or card numbers combined with required access code, security code or password to access an account).		Directly from you.	Fulfill or meet the reason you provided the information; provide you with our Services; protect and secure our environment. For job applicants: Process your application.	Payroll and benefit providers; technology providers and technology support services.	The length of your business relationship with us plus any legally required additional retention period for this category of personal information following conclusion of your business relationship with us or for the length of time necessary to fulfill our business purposes, whichever is longer.
Precise geolocation (location within a geographical area of a circle with a radius of 1850 feet or less).		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Racial or ethnic origin		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Religious or philosophical beliefs		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Union membership		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Genetic Data		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Mail, email, or text messages where the content is not directed to us.		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Unique identifying biometric information		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Personal information collected and analyzed concerning health.		We do not collect.	Not applicable.	Not applicable.	Not applicable.
Personal information collected and analyzed concerning sex life, or sexual orientation.		We do not collect.	Not applicable.	Not applicable.	Not applicable.

Rights and Opt-Outs

In addition, each of the above referenced personal information categories may be shared with government agencies or other third parties as required by law or compelled by legal process; to assignees as part of a merger or asset sale; to respond to an emergency or otherwise protect the rights, property or security of our customers, third parties, or TKKC; exercise or defend the legal rights of TKKC and its employees, affiliates, customers, contractors, and agents; or to other parties at your request (or to you directly).

Right to Access

California residents have the right to request the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect or process sensitive personal information for the purpose of inferring characteristics about consumers. We also not disclose sensitive personal information for purposes other than those specified in section 7027(m) of the CCPA regulations promulgated by the California Privacy Protection Agency. Therefore, we do not offer consumers the option to limit the use of their sensitive personal information.

Right to Opt Out of Sale

While we do not sell personal information in exchange for monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” under the CCPA. In the past twelve months, we may have provided the following categories of information to advertising networks, data analytics providers, and social media networks in ways that could be considered a “sale” under California law:

• Personal identifiers (such as unique personal identifier, online identifier, internet protocol address, device information and identifiers, unique advertising identifiers and cookies); commercial information; Internet and other electronic network activity information; geolocation information; and inference or intent data.

We may disclose these categories of information to these third parties to market and advertise our products and services; perform analytics; and to maintain, improve, upgrade, or enhance our products or services. We have no actual knowledge of selling the personal information or sensitive personal information of minors under 16 years of age.

You have the right to opt out of the “sale” of your personal or sensitive personal information. If you would like to opt out of such disclosures, you may contact us as set forth in the “How to Exercise Your Rights” section below.

Right to Correct

You have the right to request that we correct any incorrect personal information that we collect or retain about you.

Right to Delete

You have the right to request deletion of the personal information we have collected from you.

Right of Non-Retaliation and Non-Discrimination

You have the right to exercise the privacy rights conferred to you under the CCPA without receiving retaliatory or discriminatory treatment. We do not discriminate against California residents who exercise their privacy rights.

How to Exercise Your Rights

If you, or your authorized representative, would like to exercise any of your rights as described in this notice, please utilize the “Contact Us” section of our Website or call us at 855.794.2602.  When you contact us, identify the privacy right you would like to exercise and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Requesters will need to provide us with personal information in order to verify their identity and residency, including name, email, and state of residence. We will compare the information you provide with our internal records. We will only use the personal information collected during this verification process to verify your identity by comparing the data against our internal records and for no other purpose.  If you submit a request on behalf of another person, we will also require proof of authorization and verification of identity directly from the person for whom you are submitting a request.

Updates & Contacting Us

We reserve the right, in our sole discretion, to modify, update, add to, discontinue, remove or otherwise change any portion of this privacy notice, in whole or in part, at any time. When we amend this privacy notice, we will revise the “Last Updated” date located at the top of the document. If you provide personal information to us or access or use our Services after this privacy notice has been changed, you will be deemed to have unconditionally consented and agreed to such changes. The most current version of this privacy notice will be available on this page and will supersede all previous versions of this privacy notice. 

If you feel that TKKC is not abiding by this privacy notice, you should contact us immediately via the ‘Contact Us’ section of our Website or by phone at: 855.794.2602.