Privacy Policy

I. Personally-Identifiable Information and Non-Personally Identifiable Information.

TMD Smart Media (also referred to herein as “TMD SM”) may collect two different types of information, Personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“Non-PII”). PII that we collect is information that identifies you as an individual – and includes your name, address, telephone number, e-mail address, credit card information, billing address, and shipping information. Non-PII is aggregated information, demographic information, IP addresses, user behavior data from web interaction metrics tools and other information that does not reveal your specific identity. PII and Non-PII may be collected anytime you access or use a TMD SM website. PII and Non-PII may also be collected by TMD SM during in-person discussions, telephone conversations, and electronic or other written communications. TMD SM also collects information via cookies; blocking cookies may render you unable to access certain TMD SM products, services, or websites. 

TMD SM uses PII to respond to your inquiries, provide you with services you have requested, keep you informed of services TMD SM thinks may be of interest to you, and otherwise personalize your experience with TMD DM, and other reasons. TMD SM does not sell or lease PII about you to others, and may in some cases be liable for so doing under the Privacy Shield Framework outlined below. TMD SM shares your PII with TMD SM’s affiliates and third parties contracting with TMD SM to provide services to you, including financial institutions, API integrators you have chosen, and other third party software services that you have chosen. TMD SM employees who help to run our services, and those employees who provide you with customer service, along with our customer service partners, also have access to PII as part of their job in providing services to You. TMD SM may also share PII when required by law, or when you have expressly requested TMD SM to do so. TMD SM reserves the right to disclose and use your PII if TMD SM believes it is necessary to: (a) respond to legal process, e.g., a subpoena; (b) respond to a law enforcement agency’s request; (c) enforce the Terms; or (d) protect the rights, privacy, safety, property, or operations of TMD SM or third parties; 

Because Non-PII does not personally identify You, TMD SM reserves the right to use and disclose to third parties Non-PII for any purpose. 

TMD SM maintains reasonable physical, administrative and technical safeguards to protect PII from loss, misuse, or unauthorized access, disclosure, alteration or destruction. TMD SM enforces its Privacy Policy via self-assessment. 

TMD SM reserves the right to change this privacy notice, which changes will become effective upon posting of the revised notice on, or upon emailing of the changes to You at the email address You provided to TMD SM, or as required by law.

II. Links to or From Other Sites.

Except where expressly stated by TMD SM, TMD SM is not affiliated or associated with operators of any third party websites that link to or are linked from any TMD SM-maintained website. TMD SM disclaims any responsibility for the accuracy or content of information found on third party websites that link to or are linked from any TMD SM website. TMD SM disclaims any responsibility for the security of any information (including without limitation credit card and personally identifiable information (“PII”)) that you may provide to any third party. TMD SM reserves the right, at any time and in its sole and absolute discretion, to block links to any TMD SM-maintained website through technological or other means without prior notice.

III. EU-US and Swiss-US Privacy Shield Frameworks.

TMD SM complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. TMD SM has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

Under the Privacy Shield, you have the right to access, correct, or delete your personal data. You also have the right to limit TMD SM use of your data – including the right to opt-in or out of receiving communications from TMD SM. To exercise any of these rights, please send an email to [email protected]

Third party data transfer. TMD SM may be liable for the transfer of EU and/or Swiss personal data to third parties acting as our agents unless we can prove we are not responsible for the event given rise to the damages.

The Choice Principle. Note that we may be required to release personal data of EU and/or Swiss individuals in response to lawful requests by public authorities including to meet national security and law enforcement requirements.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, TMD SM commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should contact TMD SM via email at [email protected]

TMD SM has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit for more information and to file a complaint. Under certain limited conditions, individuals in the European Union or Switzerland may have the right to invoke “last resort” binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission. The Federal Trade Commission has jurisdiction with enforcement authority over TMD SM’s compliance with the Privacy Shield.

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