TessaB Privacy Policy

(Revised Sept 2021)

Please read this Privacy Policy carefully. To protect your privacy and help you to make informed choices, this Privacy Policy explains our information practices, how you can choose how we use your data, and your rights regarding your data. If you do not agree with our policies or practices, regarding our treatment or use of your information, your choice is not to use the TessaB.com website (“Site”).

In summary, we will only use your information:

• To optimize our website performance;
• For our legitimate business purposes as set forth in our Terms of Service; and
• With your consent

This is explained in more detail below.

By accessing or using this Site, and/or accepting our Terms of Service, you agree to this Privacy Policy. You must also agree to our Terms of Service and Transaction Policy in order to use the Service provided by our Platform. We may change this Privacy Policy from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

If you have any inquiries about this Privacy Policy or how we use your personal information, please contact us at [email protected].

This Privacy Policy applies to the websites and mobile applications owned and operated by IGTW Operating Company, LLC d/b/a TessaB and its subsidiaries (“TessaB”). We refer to these websites (the “Site” or “Sites”) and mobile applications (the “Apps”) collectively as the “Service,” “Services,” or “Platform” and includes the information, goods and/or services made available to users of the TessaB Network, relevant news, content, applications, and sponsored programs, advertising, email communications, and discussion forums. References to “we” or “us” mean TessaB, including any company we control.

Contents

• 1. About us
• 2. Children Under the Age of 13
• 3. What information we collect and how we collect it
• 4. How we collect Personal Information
• 5. How and why we use Personal Information
• 6. How we share Personal Information
• 7. International transfers
• 8. Data security
• 9. How long we keep Personal Information
• 10. Third party links
• 11. Accessing and correcting your information
• 12. Legal Disclosures
• 13. Changes to this policy or your data
• 14. Contacting Us

1. About Us

This website TessaB.com/ (the “Site”) is operated by TessaB Corp (also referred to as the “Company”, “we”, “us” and “our”), a limited liability company organized under the laws of the state Florida and is a data controller.

The services provided by TessaB include facilitating the purchase and sales of new and used mobile devices, together with related goods, programs and services.

If you do choose to use the Services, you must agree to the TessaB’s Terms of Service (“ToS”) and Transaction Policy which together form the contract between us and you. By accepting our ToS and Transaction Policy, you also confirm that you have read, understand and accept this Privacy Policy. If you do not want us to collect, use or share information about you and your use of the Services as described in this Privacy Policy, then you should not use the Services. By using the Services, you acknowledge that we will store, use and otherwise process your information in the United States, where we are located. Except as otherwise noted in this Privacy Policy, TessaB is the data controller responsible for the processing of your personal information as described in this Privacy Policy.

TessaB’s offices are located at:

11 Vreeland Road

Florham Park, NJ 07932

You may contact us about any questions you have regarding this Privacy Policy at either our postal address above, or by e-mail directed to [email protected].

2. Children Under the Age of 13

Our Site is not intended for children under 13 years of age. No one under age 13 may use or direct any information to the Site. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Site, use any of its features, subscribe to our mailing list, use any of the interactive links or post anything on the Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verified parental consent, we will delete that information. If you believe we may have any information from or about a child under 13, in connection with the access or use of this Site, please contact us at [email protected]

3. What Information We Collect and How We Collect It.

The type of information we collect depends on how you use the Site and how you interact with us. “Personal Information” means any data which can be associated with you as an individual, either directly or indirectly, and is collected on a voluntary basis from you.

The Personal Information we collect via the Site may include:

• Identity information, such as your name, organization name and position, postal address, e-mail address, telephone number, biographical data, social media links, and/or any other identifier by which you may be contacted online or offline.
• Technical data, such as your internet protocol (IP) address, device identifiers, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and/or platform, and other technology information relating to the devices you use to access or transact business with the Site.
• Usage data, which includes information about your use of the Site, and any communications we may receive from you.
• Marketing and communications data, including your preferences in terms of receiving marketing and other communications from us.

The Site is not intended to store or transmit “special categories” of Personal Information, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information, or criminal convictions and offenses.

4. How We Collect Personal Information

We collect information from you in two different ways.

a) Personal Information you provide to us.

If you subscribe (sign up) to our mailing list, inform us of your marketing and communications preferences, or post or submit any text, comments, photo, video, communication, information, or other material (“User Content”) on or through the Site, you will provide us with your identity, contact information, and IP address. This data is collected through direct solicitation and your voluntary submissions. You will also provide us with Personal Information when you correspond with us. We will track basic analytics (for example, open rates and click throughs) and may embed tracking codes in our regular daily email correspondence.

b) Personal Information we collect automatically as you navigate the Site.

The Site uses third party advertising providers to display advertisements based on your visits to the Site and other web sites you have visited, which allows targeted advertisements to be delivered to you for products and services about which you may be interested. The Site also uses a third party traffic measurement service to analyze how visitors use the Site, Third party advertising providers and advertisers (whose ads are displayed via the advertising provider) may use cookies, web beacons, embedded scripts (described below) or other similar mechanisms to automatically collect web site usage information, to, among other purposes, deliver advertisements, in which you might be interested, prevent you from seeing the same advertisements too many times, and to conduct research regarding the usefulness of certain advertisements to you. Cookies, web beacons and embedded scripts and other similar mechanisms used to collect web site usage information from advertising providers and advertisers, are governed by their respective privacy policy and not this Privacy Policy. We do not, however, share any Personal Information with these third parties in connection with the services they perform on the Site.

In addition, as you use the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including your browser type, the Internet Protocol (IP) address used to connect your computer to the internet, and your usage habits, patterns and preferences. We collect this data using cookies, beacons and similar technologies. We use Google Analytics to help us analyze user habits while visiting our Site. The data gathered from cookies may be transmitted to Google servers in the United States. We employ IP address anonymization to ensure that there is no direct reporting of individual user IPs as part of this process. The information will be used by Google only for the purpose of evaluating website use, creating website activity reports, and other services relating to website activity and internet usage on behalf of TessaB. The IP address that your browser conveys within the scope of Google Analytics, will not be associated with any other data held by Google.

• Chrome (http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647 or https://support.google.com/chrome/search?q=hot+to+delete+cookies&from_promoted_search=true)
• Internet Explorer (https://support.microsoft.com/en-gb/kb/278835)
• Firefox (http://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored)
• Opera (https://help.opera.com/en/latest/security-and-privacy/)
• Safari (http://support.apple.com/kb/PH5042)
• Safari for iPad and iPhone (http://support.apple.com/kb/HT1677)

You can remove cookies from your computer through the browser settings. Please note however that doing so may affect, limit or degrade your ability to use of some features on the Site and other websites. Management of cookie settings varies from one browser to another, and the “Help” menu of your web browser should provide instructions how to manage cookies. For your convenience, the links below are to instructions provided by major web browsers relating to such management in those specific browsers:

c) Information You Provide to Third Parties. If you use the Site’s interactive features to communicate with other users, or to access a third party site that is linked to the Site, the other user(s) or third party site may provide us, directly or indirectly with your Personal Information. For example, another user may post your email address and name, or a third party website may report a purchase you made from that site.

5. How and Why We Use Personal Information

a) You have given us permission to do so.

If you subscribe to our mailing list, we will send you updates and marketing information that you have consented to receive. Similarly, if you contact us with a question or comment, we may need your contact, identity, technical and/or usage information to respond.

b) We have a legitimate interest (reasonable business purpose) for doing so.

• Make the Site available, to improve it, to conduct system maintenance, support, troubleshooting, reporting and to host data;
• Ensure that the Site is secure;
• Analyze how users interact with the Site; and
• Address technical issues you may experience with the Site.

We may also use any or all of the information above to administer and manage our business in general, which include engaging in “Know Your Customer” and anti-money laundering checks as required by law, regulation, or best business practices. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.

c) How We Collect and Use Mobile Device Information

Your use of the Platform requires that you download, install and run our mobile diagnostic application (“TessaB Connect”) software, which we use to confirm device functionality in connection with any potential purchase or sale of mobile devices through the Platform. TessaB Connect collects certain mobile device identifier information, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.

d) We need to comply with a legal or regulatory obligations.

In certain circumstances, we may need to retain or use your data to comply with laws or regulations.

6. How We Share Personal Information

We may share your information with our trusted third party service providers (including information technology providers such as website and mailing list hosts). We may provide your account information to companies that help us with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.

When we share your information with our service providers, we will take commercially reasonable steps to help ensure that your data is kept secure and used only in accordance with this notice.

We may share Personal Information when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government investigation or inquiry), to detect, investigate and defend against fraudulent or unlawful activity and violations of TessaB’s Terms of Service, to enforce or apply our Terms of Service or other agreements, in the context of a Company reorganization, or to protect the rights, property, or safety of the Company, our employees, users, or others.

Investigations. We may use your information to detect, investigate and defend against fraudulent or unlawful activity and violations of our Terms of Service .

7. International transfers

This Site is hosted on servers located in the United States, and the use of this site is currently intended for and restricted to users in the United States. TessaB will endeavor to meet those data protection laws and regulations (including the General Data Protection Regulation, or “GDPR,” when and as applicable) to which we may be subject.

General Data Protection Regulation

General Data Protection Regulation (“GDPR”) was passed by the European Parliament and establishes a standard for data privacy for all member states of the European Economic Area (“EEA”) (“EU”). It purpose, with certain limitations and exceptions, is to give EEA residents (described as “data subjects” by the GDPR) certain rights over their Personal Information, including, the:

• Right of access: Individuals can ask for a copy of the Personal Information retained about them and an explanation of how it is being used.
• Right to rectification: Individuals have the right to correct, revise or remove any of the Personal Information retained about them at any time.
• Right to be forgotten: Individuals can ask to delete their Personal Information. At your request, we will remove your contact information from the system, and we will not contact you again.
• Right to restrict processing: If an individual believes, for example, that their Personal Information is inaccurate or collected unlawfully, the individual may request limited use of their Personal Information.
• Right of portability: Individuals have the right to receive their Personal Information in a structured, commonly used and machine-readable format.
• Right to object: Where an individual decides that they no longer wish to allow their Personal Information to be included in analytics or to receive direct marketing emails or other personalized (targeted) marketing content at any time, the individual may opt out of use of their data for these purposes.

If you are a data subject falling under the scope of the GDPR, you can exercise the above rights. Please note that these rights are not absolute, and limitations/exceptions may apply in some cases.

In respect of transfers outside of the country, we either implement the Model Clauses pursuant to Commission decision 2004/915/EC or 2010/87/EU (as appropriate) with the recipient of your Personal Information; and/or ensure that the recipient of your data is registered with the EU-US Privacy Shield.

You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.

8. Data Security

The safety of your Personal Information is important to us, and we use various technical and organization measures to secure it.

We employ commercially reasonable encryption (TLS technology), data security, and intrusion prevention technologies to protect and secure all personal information in our possession. Our data environment is monitored 24/7 for malicious activity and/or anomalous behavior either of which triggers our incidence response. However, the transmission of information via the Internet is not completely secure, and unfortunately, no method of transmission over the internet or method of electronic storage is completely secure. Although we take commercially reasonable measures to safeguard against unauthorized disclosures of information, we cannot guarantee the security of your data. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. You acknowledge and agree that you are solely responsible for maintaining the security and confidentiality of your account username and password.

9. How Long We Keep Personal Information

We will retain your Personal Information only for as long as it necessary to fulfill the purposes for which we collected it, including satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of that Personal Information, the purposes for which we processed the data and whether we those purposes may be achieved by another means, and the applicable legal requirements

10. Third Party Links

This Site may contain links to other websites whose information practices may be different than ours. Please consult all third party Sites’ privacy notices. We have no control over third party websites, and disclaim any and all responsibility and liability in connection with any information that you submit to, or permit to be collected by, such third party websites.

11.Accessing or Correcting Your Information

You can review and change your personal information by logging into the Site and visiting your account profile page, or by sending an email to us at [email protected] to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Site, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Site users. Proper access and use of information provided on the Site, including User Contributions, is governed by our Terms of Service. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.

 

12.Legal Disclosures

We may need to share your data when we believe it is required by law or to help protect the rights and safety of you, of us or of others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations. In such circumstances, our only obligation to you is as follows: We will attempt to notify you through the contact information you have provided to us about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. Notwithstanding the foregoing, we may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

13. Changes to this Privacy Policy or Your Data

We may amend this Privacy Policy from time to time. We will post any update to this Privacy Policy on the Site. It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during our relationship. We reserve the right to modify this Privacy Policy at any time and any changes will be effective upon posting of the modified Privacy Policy unless we advise otherwise. If we make any material changes to this Privacy Policy we will notify you by email (sent to the email address included in your account profile) and/or by means of a notice on the Sites before the change becoming effective. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices. By continuing to use the Services after changes are made to this Privacy Policy, you agree to such changes.

14. Contacting Us

If you have general questions about your account or the Services, contact us at [email protected]. For questions about this Privacy Policy or how your personal information may be used when you use the Services, please contact our Privacy Office by email at [email protected] or at the following address:

11 Vreeland Road

Florham Park, NJ 07932

15. General Data Protection Regulation (“GDPR”) Addendum and California Consumer Privacy Act

If you are in the European Economic Area, and in addition toTessaB’s Privacy Policy, you consent to our General Data Protection Regulation, (“GDPR”) policy shall apply in connection with our collection, use and processing of yourPersonal Information (as defined by the GDPR)that you provide to us in connection with your use of the TessaB.com web site (“Site”).

Designated Countries. By visiting the Site and/or providing us with information, you acknowledge, agree and consent that your Personal Information (also referred to as “Personal Data”) may be processed for the purposes identified in the Privacy Policy and in this GDPR Addendum. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your information, you consent to such transfer. If you reside in the “Designated Countries,” as defined in the GDPR we will be the controller of your Personal Information provided to, collected by or for, or processed in connection with your engagement. We use the term “Designated Countries” to refer to countries in the European Union (EU), the European Economic Area (EEA), and Switzerland.

For purposes of our Terms of Service, Privacy Policy, and GDPR consent, “Personal Information” means information that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing information.

Clicking “I Agree” below, confirms your express consent to the processing of the Personal Information you provide to us for the purposes stated below. The central nature of our businessis providing a platform for the purchase and sale of mobile devices and related goods and services, including the TessaBdigital incentive activity, together with, relevant news, reference content, applications, sponsored programs, advertising, email communications, and discussion forums (“TessaB Services”).

Accordingly, in order for you to register with us and use the Site, you hereby acknowledge and agree that to the uses described above and the collection and processing of your Personal Information provided by you to us or to our data processor.

 

How We Use Your Personal Information

We may use your Personal Information to provide you with Services as set forth in the Terms of Service and Privacy Policy, including personalizing the Services for you;

• Market our products and services to you that we believe may be of interest to you. For example, we allow advertisers to choose the characteristics of users who will see their advertisements and we may use the attributes we have collected to select the appropriate audience for those advertisements;
• Respond to your requests, resolve disputes and/or troubleshoot problems;
• Improve the quality of the Site and the Services; and
• Communicate with you about the Site and the Services.

We may also use your Personal Information to create Anonymous Information records by excluding information that makes the information personally identifiable to you.

Right to Withdraw

If you reside in, or are a citizen of a Designated Country (as defined above), you have the right to withdraw your consent at any time; provided that if such consent interferes with or causes us to violate a contract involving you, you agree to indemnify us for any damage or financial penalty incurred as a result of the withdrawal of our consent.

Right to Access

You have the right to access the Personal Information that we may hold about you and the purposes for which we are using it in a structured, commonly used and machine readable format. We may ask for proof of your identity. On receipt of such a request, we will endeavor to respond to you as soon as possible, at most within one calendar month.

Right to Restrict or Transfer

You have the right, under certain circumstances, to require that we restrict the processing of information that we have about you. You also have the right to request that your Personal Information be send to a third party.

Right to Rectification

You have the right to request that we amend any Personal Information which is incorrect or requires updating.

Erasure

You have the right to request that we delete any Personal Information pertaining to you, subject to any legally imposed retention requirements to which we may be subject. We will assess any deletion request on a case by case basis and will endeavor to respond to you as soon as possible, at most within one calendar month. If you have authored any content on the Site, and would like this to be deleted, please let us know.

How We Use Your Information and Data

We will use your Personal Information insofar as it is regulated by the GDPR to conduct our business, specifically: pre-market and marketing, reference content, applications, sponsored programs, advertising, email communications, and discussion forums in connection with the purchase and sale of mobile devices and related goods and services.

California Consumer Privacy Act of 2018

TessaB will endeavor to comply with the California Consumer Privacy Act of 2018, as effective January 1, 2020

You also have the right to lodge a complaint with the Information Commissioner’s Office (“UK-ICO”), which is the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, be grateful if you would contact us in the first instance so we can endeavor to deal with your concerns direct.

If you would like to exercise any of these rights or are concerned with the manner in which we have collected or used your Personal Information, please contact us at the following address and provide the following details:

If you are wish to exercise any of these rights, please contact us [email protected],

or by postal mail at:

11 Vreeland Road

Florham Park, NJ 07932

NOTE: [DIALOG BOX w/CLICK-THROUGH}

By clicking “OK” I agree to TessaB’s Privacy Policy and where applicable TessaB’s GDPR Addendum. Once you have clicked “I Agree”, we will send you an email confirming your registration with us. Your reply to that email constitutes a second confirmation of your agreement to our Terms of Service, Privacy Policy, GDPR Addendum, and Transaction Policy. This double opt-in also serves as confirmation of your acknowledgement and consent to our collection, use and processing of your Personal Information as defined herein and in our Privacy Policy.