Last Updated 07/06/2025
As a commercial business, Todd Moses & Company LLC (“TM & Co”) may collect, use, and disclose personal data as part of our standard operations. When a TM & Co entity acts as the data controller (meaning we decide why and how your personal data is used), this Statement outlines how we handle that data in compliance with data protection and consumer privacy laws. Additionally, this Statement explains your rights regarding your personal data.
This Statement outlines how we use and protect personal data on a global scale. If you reside or work in certain countries, states, or territories, additional information is provided at the end of this Statement regarding our handling of your personal data.It's important to clarify that this Statement does not apply to personal data processed on behalf of our customers. When we offer our products and services, we act as a data processor. This means our customers are in control of the personal data and other information processed through our products or services, and they dictate how that data is managed. As a data processor, we adhere to our customers' instructions for processing in accordance with applicable laws.
Therefore, this Statement does not pertain to our customers' processing of personal data while using TM & Co products or services. If you want to understand how one of our customers handles personal data using TM & Co products or services, or if you wish to exercise your rights concerning any personal data they process, please refer to the relevant customer’s privacy statement. This is the best way to learn about those practices or to find their contact information.
As you engage with our services or communications, you may come across links to third-party websites that are outside of TM & Co's control. These links may allow you to share information with those website controllers. We are not responsible for the privacy policies or the data collection, use, or disclosure practices of our customers or any third-party sites, unless we indicate otherwise. To understand how they process your personal data, we encourage you to review the privacy policies of each website you visit.
TM & Co collects personal data through three main sources:
1. Personal Data You Provide: This includes information you submit directly, such as through forms or correspondence.
2. Automatic Data Collection: We gather personal data automatically when you visit TM & Co websites, as described in the Technical Data section below.
3. Data from Other Sources: This includes personal data obtained from service providers, business partners, and publicly available information.
Contact Data: This includes your name, address, email address, telephone number, mobile number, country of residence, and social media handles. We may collect this information directly from you, your employer, publicly available sources, or through third-party partners who provide networking contact information.
Professional Data: This encompasses your company name, occupation, contact details, employment history, areas of expertise, and your experience with TM & Co products and services. Similar to Contact Data, we may gather this information from you, your employer, publicly available sources, or third-party partners.
Transaction Data: This includes details about products and services purchased, licenses acquired, types of products or services of interest, and eligibility information, such as whether your company is a customer of TM & Co. This data is collected during the purchase process of our products and services.
Payment Data: This consists of payment or billing information, including tokenized payment details when necessary. We may collect this information when you sign up for TM & Co products or services or during your use of our website for purchases.
Technical Data: This includes your IP address, operating system, browser information, and user agent. We also collect identifiers like cookie IDs and mobile device IDs, along with data from your interactions with TM & Co websites. For example, when we send marketing communications, we track whether you opened the email or clicked any links.
Training and Educational Data: This may include registrations for courses, assessments you signed up for and/or completed, results from those assessments, and issued certifications. We collect this data when you enroll in a training or certification program or generate it upon completion of an event.
Communication Data: This includes messages, correspondence, and any data you create while communicating with TM & Co through various channels such as post, SMS, email, social media, and forums. We may collect this information from your interactions with TM & Co employees, contractors, and service providers.
Audiovisual Data: This comprises images and audio, including photographs and recordings taken through security systems or at events, such as when you participate in a TM & Co event or visit our offices.
Inferred Data: This represents data generated by analyzing preferences or interests in TM & Co products and services. It is derived by combining various data types (such as Contact, Professional, Transaction, Technical, and Communication Data) collected by TM & Co with information from third parties, aiding in product sales and compliance with laws.
Contact Preferences: This includes the consents or preferences you provide to us regarding how you wish to be contacted and which TM & Co products or services interest you.
Feel free to reach out if you have any questions or need additional information!
The following lets you know how and why we use the personal data we collect:
1. To conduct our business operations and provide our products and services:
To communicate with you: We use your information, including Contact Data and Communication Data so that we can communicate with you, answer your queries, or get in touch to understand if you are interested in TM & Co products and services.
To provide you with our products and services: We use your information, including your Contact Data, Payment Data, Technical Data, Communication Data, Professional Data, and Training and Educational Data, depending on the services provided, for various reasons, including to:
Verify your identity;
Send communications relating to the product or service purchased;
Provide you with our products and services including training services;
Fulfil our contract with you.
To process financial transactions: We use your information, including Contact Data, Communication Data, Payment Data and Transactional Data to process transactions and to provide you with TM & Co products and services. When you make a payment on our website, our payment processor, Stripe, collects your Payment Data and Contact data directly from you. TM & Co does not provide Payment Data to Stripe. As a result, Stripe is an independent controller of information provided in the course of using Stripe’s payment processing service on TM & Co platforms.
To analyze activity on our websites, improve our public facing platforms and communications: We use your information, including Technical Data, Communication Data and Training and Certification Data to understand how you use our websites, forums or training platforms and to understand and improve your experience of those websites, training platforms and the communications we send.
To enable business transfers and transactions: We process your information in connection with transactions if there is a proposed or actual merger, purchase, sale acquisition, financing due diligence, transition of service to another service provider, divestiture, bankruptcy, restructuring, receivership, reorganization, dissolution or other sale or transfer of some or all of TM & Co’s assets, in which personal information processed by TM & Co pursuant to this Statement forms part of the assets transferred or sold.
To ensure compliance with our obligations: We may access, preserve, process, or disclose your information, where required, to comply with a court order or legal requirement, including to respond to governmental or regulatory requests, enforce our policies and contracts, collect amounts owed to us, or assist with an investigation or prosecution of suspected or actual illegal activity.
To protect the rights, property, life, health, safety or security: We process your information, where required, to protect the rights, property, life, health, safety or security of TM & Co, our employees, our users (including you) or others.
To measure, develop and improve our products and services: We process your information, including Contact Data, Technical Data, and Communication Data to develop, improve and measure the performance of our products and services.
To create de-identified and aggregated information: We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about the device from which you assess our services, or other analysis we create.
2. To enable our sales and marketing functions to carry out marketing related to TM & Co products and services:
To send sales and marketing communications: We use your Contact Data, Professional Data, Technical Data, Communication Data, Transaction Data, Training and Educational Data, Inferred Data and Contact Preferences to send you marketing communications about TM & Co products and services you have purchased or attempted to purchase, or communications about TM & Co products and services we think you might be interested in purchasing or events you might wish to attend, and to carry out targeted marketing campaigns including posts to third party platforms such as social media platforms and networking websites.
To understand who would be most interested in our products and services and to personalize our communications: We use your Contact Data, Communication Data, Professional Data, Technical Data, Transaction Data, Training and Educational Data, Inferred Data and Contact Preferences to understand who may be interested in our products and services to personalize our communications with you, including sending marketing communications.
To analyze the effectiveness of our communications: We use your Contact Data, Communication Data and Technical Data to understand the impact of our communications, for example to understand the effectiveness of our marketing campaigns and to improve them going forward.
To target advertising: We use your Contact Data, Professional Data, Communication Data, Technical Data, Transaction Data, Training and Educational Data, and Inferred Data to target advertisements and messages to you, this can include targeted advertising via third party advertising platforms including search engines and social media/networking platforms such as LinkedIn or Twitter.
3. To manage your visit to a TM & Co managed space or event:
To enable your visit to a TM & Co designated space: Depending on how you engage with TM & Co’s facilities when you visit our designated spaces or offices, we process your Contact Data, Communication Data, Professional Data, Technical Data and Audiovisual Data when you attend a TM & Co designated space such as offices or pop-ups.
Event management: Depending on the event or how you engage with TM & Co in the course of an event hosted, or co-hosted by TM & Co, we process your Contact Data, Professional Data, Communication Data, Audiovisual Data and Technical Data to enable your attendance as TM & Co hosted or affiliated events such as conferences or webinars. We may also process information we receive, including from our partners, during such events to understand whether you are interested in our products or services so that we can present you with the most relevant information on our products and services at the relevant event or in post event communications.
4. To comply with legal obligations and maintain the physical and information security of TM & Co’s products and services, employees and partners:
To comply with legal obligations: Where necessary, we use your personal data, including Contact Data, Technical Data, Communication Data and Government Identifiers, where necessary, to comply with legal obligations such as tax reporting, regulatory requirements or fulfilling your rights request.
To help you exercise your rights and control over your personal data: Where you contact us to exercise your rights as a data subject or to opt-out from certain forms of communication, we may need to further process your personal data such as Contact Data, Communication Data and any applicable personal data together with any Government Identifiers you may provide, to comply with your request (for example, if you request a copy of your personal data and you provide your ID to confirm your identity).
To protect our business, our affiliates, and others: We process your personal data which can include Contact Data, Professional Data, Payment Data, Transaction Data, Technical Data, Audiovisual and Communication Data to monitor for, or detect, fraudulent, harmful or illegal activity.
TM & Co may disclose or transfer personal information that we process as required in the course of operating our business to the following recipients and purposes:
TM & Co affiliates: Personal data is disclosed to and from TM & Co Technologies Inc. and its affiliates to enable and fulfil our business operations requirements. Affiliates are bound by contractual obligations to process any personal information in compliance with data protection and consumer privacy laws that apply.
Service providers: We disclose information as needed to our agents, contractors and service providers. These parties are bound by contractual obligations to keep personal data confidential and use it only for the purposes of providing services for, or with, us. Examples of service providers include marketing and sales services, event management, website hosting and training providers.
Third Parties: We disclose your personal data to third parties, including third party partners where applicable to:
Verify your identify when signing up for products and services;
To provide payment processing services;
Provide the result of any training course or quiz you complete with us to your employer where you have taken part in training or certification as part of an employment requirement;
Enable business transfers to a buyer or other party to a transaction if there is a proposed or actual merger, purchase, sale acquisition, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of TM & Co’s assets, in which personal data processed by TM & Co pursuant to this Statement, forms part of the assets transferred;
Disclose personal data to our partners when offering co-branded services, selling or distributing our services, running branded events with our partners, or engaging in joint marketing activities;
Show you relevant adverts – we may disclose pseudonymous data with advertising networks as set out in more detail in Cookies and Similar Technologies;
Comply with a court order or legal requirement, including to respond to government, regulatory requests, tax authorities, police agencies, public prosecutors, civil disclosure requests or judicial requests; and
Protect the rights, property, life, health, safety or security of TM & Co, our employees, our users (including you), our products and services, or others.
We may also disclose personal data to third parties at your request or direction. You also may provide personal data directly to third parties, such as when inputting credit card information on our websites to purchase products or services. In this case the information is processed directly by our payment processor partner.
We use cookies and similar technologies, such as pixels and beacons, to understand how you interact with our websites, communications, advertisements, or content on third-party platforms. For more information about the types of cookies we use and how to manage them on your device, please refer to our Cookies Statement.
If you activate a social media plug-in, the respective social media platform will automatically provide content to your browser, which will then be integrated into our websites. In this case, personal data may be transferred, initiated and controlled by the social network, such as LinkedIn. Your connection to the social media platform, the personal data transfers that occur between the platform and your system, and your interactions on that platform are solely governed by the data protection policies of the relevant social media network.
We collect and retain personal data only as necessary or permitted for the purposes outlined in this statement. This is based on the original reason for collecting the data and what is allowed under applicable laws.
We store the personal data we collect according to our internal data retention policies for as long as you use our services or for the time required to: (i) fulfill the purposes for which we collected the personal data; (ii) provide and secure our products and services; (iii) resolve disputes, establish legal defenses, enforce our agreements, and comply with applicable laws; (iv) conduct audits; and (v) adhere to our internal policy requirements.
Our websites are not designed for children under 16 years of age. If you find out that your child has provided us with personal information without your consent, please contact us, and we will take steps to delete that information. We do not knowingly collect personal information from children under 16, as defined by the U.S. Children’s Online Privacy Protection Act (COPPA).
In various countries and territories, data protection and consumer privacy laws grant individuals certain rights concerning their personal data processed by organizations. If you live or work in the UK, EEA, or Switzerland, you have the following rights regarding the personal data processed by TM & Co. If you reside or work in another country that offers similar rights, you may also have some or all of the rights listed below concerning your personal data processed by TM & Co.
Please note that these rights are not absolute and may need to be balanced with other considerations, including the privacy rights of other individuals.
1. Right of Access: You have the right to request confirmation about whether we process your personal data. If we do, you are entitled to access that personal data and obtain information on how we process it.
2. Right to Correction: You may request the correction of any personal data we hold on you if it is inaccurate or incomplete.
3. Right to Erasure: Under certain circumstances, you may request the deletion of your personal data if specific grounds for erasure apply.
4. Right to Restrict Processing: In some cases, you may have the right to restrict how we use your personal data. When processing is restricted, we may still store your personal data but cannot use it unless we have your consent, need it for a legal claim, or for important public interest reasons.
5. Right to Object: You may have the right to object to the processing of your personal data in certain situations, including:
(i) Objection to processing based on our legitimate interests,
(ii) Objection to processing for direct marketing purposes (including profiling).
6. Right to Data Portability: In specific circumstances, you may have the right to obtain and reuse certain personal data in a structured, commonly used, and machine-readable format. You may also have the right to have that personal data transferred directly to a third party, subject to certain conditions.
7. Right to Withdraw Consent: If you have given us consent for processing your personal data, you have the right to withdraw that consent at any time. Please note that this withdrawal will only apply to future processing and will not affect the legality of any processing carried out prior to the withdrawal.
8. Right to Lodge a Complaint: If you believe our processing of your personal data violates legal requirements, and if such a right exists in your country, you can lodge a complaint with your competent data protection authority or consumer privacy supervisory authority.
- If you are in the UK, you may complain to the Information Commissioner’s Office using this link.
- If you are in the European Economic Area, you can find details for the data protection authority in your country.
Depending on your country of residence, you may have additional rights not listed here.
If you live in France, applicable laws grant you the right to provide instructions regarding the handling, retention, and deletion of your personal data after your death. This may include nominating a "data executor" responsible for following your instructions. To exercise this right, clearly specify your preferences about the management of your personal data, including retention, deletion, and disclosure to third parties.
You can modify or revoke your instructions at any time. To designate a data executor, please provide their full name, contact information, and relationship to you. The data executor must be a natural person capable of carrying out your instructions.
Please be aware that your instructions and the designation of a data executor do not guarantee that your personal data will be exempt from disclosure if required by law, regulation, or court order.
To exercise your rights mentioned above, please send your request to the email address or physical address provided below. If you are not satisfied with how we handle your personal data, we encourage you to let us know. We will investigate any concerns you raise. For any inquiries, please contact our Data Protection Officer.