PRIVACY POLICY
              We understand that providing personal information online involves a great deal of trust on your part; we take this trust very seriously, and make it a high priority to ensure the security and confidentiality of the personally identifiable information (“personal information”) you provide us.
              
              This Policy discloses our personal information privacy practices.  We (also “us” or “our”) are TGP Solutions LLC and its representatives, members, affiliates and subsidiaries. We operate the www.tgp-solutions.com, www.tiresync.com, www.tgpfitments.com, and www.tgpwidget.com websites and other related websites.  These websites may be referred to as the “Sites” in this Privacy Policy. The Sites are intended for use by residents of the U.S.A. and Canada that are over 18 years of age.
              
              Each Site is governed by Terms of Use.  By accepting the Terms of Use for each Site, you also consent to our collection, use and disclosure of your personal information, as provided in this Privacy Policy.  Capitalized terms used in this Privacy Policy have the definitions given such terms in the Terms of Use for each Site unless otherwise defined in this Privacy Policy.
              
              If you have entered into a Separate Agreement (such as a license) with us for use of our products and services (including Services and Software, as defined in the Terms of Use), the provisions of the Separate Agreement will govern use and disclosure of all personal information and other information related to the Separate Agreement.  If there is any conflict between this Privacy Policy and a Separate Agreement that governs any information, the Separate Agreement will take priority over this Privacy Policy with respect to that conflict and information.
              
              A SPECIAL NOTE ABOUT CHILDREN
              
              Our Sites are general audience websites, and we do not direct any of our content specifically at children under 13 years of age.
              
              Children are not eligible to use the services available on our Sites and we ask that minors (under the age of 18) do not submit any personal information to us.  If you are a minor, you can use our Site Services only in conjunction with your parents or guardians.
              
              We understand and are committed to respecting the sensitive nature of children’s privacy online.  If we learn or have reason to suspect that a Site user is under age 13, we will promptly delete any personal information in that user’s account.
              
              INFORMATION WE COLLECT ABOUT YOU
              
              Client Information
              
              You may become a “Client” on our Sites by opening an account with us.  In order to open a Client account, our representative collects personal information, such as your name, title, company name, address, email address, telephone numbers, and fax numbers.  Our representative may also assign you a Client user name and password when your Client account is opened.
              
              Developer Information
              
              You may act as a service provider (a “Developer”) to one of our Clients.  For example, you may provide website development and maintenance services to a Client.  In such cases, you may also open an account with us, which is tied to the Client’s account and may allow you to download TGP products on behalf of the Client. In order to open a Developer account, our representative collects personal information, such as your name, title, company name, address, email address, telephone numbers, and fax numbers.  Our representative may also assign you a Developer user name and password when your Developer account is opened.  For purposes of this Privacy Policy, Developer accounts, user names and passwords are considered to be the same as, and are treated the same as, Client accounts, user names and passwords, respectively.
              
              Contacting TGP
              
              When you contact us through our “Contact Us” webpage, we collect personal information, such as your name, telephone number, email address, and any information you include in the message box.
              
              When you contact us by telephone, email or another means (such as to submit a question, comment or suggestion on the Sites, or request assistance with logging onto the Sites or accessing your Client account), we may collect personal information, such as your name, telephone number, email address, Client account information (if you are a Client or Developer), and other information you choose to disclose to us.
              
              Separate Agreements
              
              The Sites may make TGP products (such as Software) available for download.  If so, you will typically be required to enter into a Separate Agreement for use of such TGP products.  In entering into this Separate Agreement, we collect personal information, such as your name, title, company name, address, email address, telephone number, company entity type and formation jurisdiction, company website address, your IP address, and other information related to the Separate Agreement.  We may collect similar information each time a Separate Agreement is amended or supplemented and when you download an update to any TGP product.  The Separate Agreement also typically specifies the TGP products licensed, the pricing structure, use and data limitations, and other provisions and information.
              
              TireSYNC™
              
              If you access and use TGP’s TireSYNC™ system through the www.tiresync.com Site or a related website, you are also assigned one or more API_Keys (which may also be termed “API Access Key” and “API Pass Key”).  We also collect information related to your usage of the TireSYNC™ system, such as statistics regarding the quantity, identity and timing of data access using the system.
              
              tgpWidget™
              
              If you access and use TGP’s tgpWidget™ system through the www.tpgwidget.com Site or a related website, you are also assigned one or more tgpWidget Codes.  We also collect information related to your usage of the tgpWidget™ system, such as statistics regarding the quantity, identity and timing of data access using the system.
              
              tgpFitments™
              
              If you access and use TGP’s tgpFitments™ system through the www.tpgfitments.com Site or a related website, we also collect information related to your usage of the tgpFitments™ system, such as statistics regarding the quantity, identity and timing of data access using the system.
              
              OTHER INFORMATION WE COLLECT ABOUT YOU
              
              Some information may be collected automatically every time you visit our Sites. This information is described below.
              
              Cookies and Other Web Technologies
              
              When you access our Sites as a Client or visitor, we may collect information about your computer and assign you a "cookie" (a small, unique identifier text file). You do not provide this information -- it is collected automatically as a means of supporting your use of our Sites. The cookie assigned may be a “session” cookie file (deleted at the end of the session) or permanent cookie file on your computer's hard drive.  The cookie may or may not contain any personal information. You can always choose to not receive a cookie file by enabling your web browser to refuse cookies or to prompt you before accepting a cookie. Be advised that, by refusing to accept a cookie, you may not be able to access some services offered by us on our Sites.
              
              Computer Information
              
              We may collect certain technical information from your computer each time you request a page during a visit to our Sites. This information is collected from your computer's Web browser and may include your IP address, operating system, web browser software (e.g., Google Chrome or Internet Explorer), screen resolution, internet service provider, clickstream data, date/time stamp, and referring/exiting websites. Wireless users (if you are using your cellular phone or other mobile device to access the Internet) should check with their wireless company to understand whether personal information may be used to identify them.
              
              USE OF YOUR INFORMATION
              
              General
              
              Information collected by us may be used to:
                  • License TGP™ products (including Software) to you
                  • Permit you with access to TGP™ products (including Software)
                  • Register you as a TGP™ Client or Developer
                  • Provide you with information through your Client / Developer account
                  • Send email notifications related to Separate Agreements
                  • Send email notifications related to TGP™ products and documentation
                  • Send email notifications for special promotions
                  • Respond to your questions, comments or suggestions
                  • Improve the quality of our products and your visit to our Sites
              
              Contacting TGP
              
              When you contact us through our “Contact Us” webpage, we may use the information you have provided to us through such webpage (as well as other information you may have provided to us) to respond to you and for other purposes related to the reason for your contact.
              
              TGP Products / Separate Agreements
              
              If you download or otherwise access TGP products (including Software) through the Sites, we use your personal information to prepare the Separate Agreement (license) for your use of such products.  We may also use and disclose all of your personal information as we deem necessary in administering, enforcing and all other matters related to your Separate Agreement (or your Client’s Separate Agreement if you are a Developer).  We may also use your email address, address, telephone number, and other contact information to contact you in matters related to your Separate Agreement.  We may use your email address, address, telephone number, or other contact information to inform you of updates, changes and other matters related to the TGP products or your Separate Agreement.
              
              Client Accounts
              
              If you register to become a Client, we use your information to create your Client account.  We may also use your information in managing your Client account, such as by preparing product updates for you and sending you notices and information regarding your Client account.  Except as provided otherwise in the Terms of Use or a Separate Agreement, we may terminate your Client account at any time for any reason, with or without cause, and without notice to you.
              
              Access to your Client Account
              
              When you access your Client account, we use your personal information (Client user name and password) as a security measure to be sure that you have authorized the access to your Client account.
              
              Developer Accounts
              
              If you register as a Developer, we use your information to create your Developer account.  We may also use your information in managing your Developer account, such as by preparing product updates for you and sending you notices and information regarding your Developer account.  Except as provided otherwise in the Terms of Use or a Separate Agreement, we may terminate your Developer account at any time for any reason, with or without cause, and without notice to you.
              
              Access to your Developer Account
              
              When you access your Developer account, we use your personal information (Developer user name and password) as a security measure to be sure that you have authorized the access to your Developer account.
              
              Access to TireSYNC™
              
              When you access the TireSYNC™ system using the www.tiresync.com Site and related websites, we use your personal information (Client API_KEY) as a security measure to be sure that you have authorized the access to the TireSYNC™ system.  We may use information regarding your use of the TireSYNC™ system in matters related to any Separate Agreement, such as determining your compliance with the Separate Agreement and any related agreement(s).
              
              Access to tgpWidget™
              
              When you access the tgpWidget™ system using the www.tgpwidget.com Site and related websites, we use your personal information (such as your assigned tgpWidget Code) as a security measure to be sure that you have authorized the access to the tgpWidget™ system.  We may use information regarding your use of the tgpWidget™ system in matters related to any Separate Agreement, such as determining your compliance with the Separate Agreement and any related agreement(s).
              
              Access to tgpFitments™
              
              When you access the tgpFitments™ system using the www.tgpfitments.com Site and related websites, we use your personal information as a security measure to be sure that you have authorized access to the tgpFitments™ system.  We may use information regarding your use of the tgpFitments™ system in matters related to any Separate Agreement, such as determining your compliance with the Separate Agreement and any related agreement(s).
              
              Special Promotions
              
              The Sites may have special promotions from time to time.  We may use your email address to send you communications regarding these special promotions.  If you notify us that you do not wish to receive communications for special promotions, we will not send them to you. One or more of our representatives may assist us in facilitating the distribution of survey or promotion programs. The representatives may use your name, email address, and other contact information for such purposes.  See SHARING OF YOUR INFORMATION, Corporate Affiliates, below.
              
              Customer Support or Questions/Suggestions
              
              If you request assistance with logging onto the Sites or accessing your Client / Developer account or the TireSYNC™ system or the tgpWidget™ system, we may use your email address, address, telephone number, and other information to respond to your request.
              
              Account Closure
              
              If you or we close your Client / Developer account, we may use your information to complete the account closure.  We may also use your email address and/or address to send you a Client / Developer account closure confirmation.
              
              Other Responses
              
              In other cases, we may use your name, email address, address, telephone number, and/or other pertinent information to respond when you submit a question, comment or suggestion.
              
              Improving the Quality of Your Visit to Our Sites
              
              When you browse the Sites, you do so anonymously. Personal information is not collected. Each Site may track information about the visits to that Site. For example, statistics are compiled that show the daily number of visitors to a Site, the daily requests received for particular files on a Site, and what countries those requests come from. These aggregated statistics are used to customize our Sites to better meet your needs and may also be provided to others, but the statistics contain no personal information and cannot be used to gather such information.
              
              We may collect information about your computer (not your name, address, e-mail address, or telephone number) through your permanent cookie file for the purpose of assessing the effectiveness of Site content and traffic. This data allows us to improve the quality of your visit by streamlining your ability to navigate the Sites and develop featured programs and content that will be of interest to our Clients and Site visitors.  In addition, we use information collected from your computer, which does not identify individual users, to analyze trends, to administer the Sites, to track users’ movements around the Sites, and to gather demographic information about our user base as a whole.
              
              SHARING OF YOUR INFORMATION
              
              General
              
              TGP does not sell or rent your personal information to anyone.
              
              Corporate Affiliates
              
              We may share your personal information among our member, representative, subsidiary, parent, and affiliated organizations, but the information will be used by them for internal purposes only and for purposes related to the Sites and your Client / Developer account and Separate Agreement.
              
              For example, TGP uses affiliated, but separate organizations (such as Pearl Communications Inc., and Tire Guides, Inc.) to act as our representatives in matters related to maintaining the Sites and marketing, licensing and supporting TGP’s products.  If you direct a communication to TGP, that communication may be forwarded to one of our representatives, which will respond to you as TGP’s representative.
              
              TGP and our representatives may each act as a data collector and/or a data processor with respect to your personal information that we collect and use.
              
              It is possible that we, our members, representatives, subsidiaries, affiliates, joint ventures, business assets, or any combination of these, could merge with or be acquired by another business entity. Should such a combination or result occur, you should expect that all of your personal information will be transferred to the merging or acquiring business entity. We cannot assure, however, that the new entity will follow the practices disclosed in this Privacy Policy.
              
              OUR PARTNERS
              
              We may partner with reputable third parties to offer our Clients and Site visitors a variety of products and services. All services throughout our Sites that are provided by a third-party partner are described as such in this Privacy Policy or elsewhere in the Sites. Although we only work with reputable third parties, our business partners may have different privacy policies and practices than we do. We encourage you to review our business partners' privacy policies to further understand their procedures for collecting, using, and disclosing your personal information.
              
              OUR LEGAL OBLIGATIONS
              
              We may be required by law or legal process to disclose personal information and other information you have provided us in your use of our Sites or related services. We may also disclose information to enforce the Terms of Use or a Separate Agreement or related agreement (such as a developer agreement), as well as to protect us and/or our Clients and users against someone who poses a threat to our interests (such as customer fraud) or whose activities could bring harm to others. As a result, we may, in our discretion, disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringement, or other activity that is illegal or may expose you or us to legal liability. We may also disclose any information about you that may be required by a court or tribunal or through some other proper legal process. Some of these rights to disclose information are further described in the Terms of Use that govern use of our Sites.
              
              OTHER WEBSITES
              
              There may be places throughout our Sites that may link you to other websites that do not operate under our information privacy practices. When you click through to these websites, our information privacy practices no longer apply, and we are not responsible for use or disclosure of information obtained from you through such websites. We recommend that you examine the privacy statements for all third party websites to understand their procedures for collecting, using, and disclosing your information.
              
              OTHER DISCLOSURES
              
              We cannot ensure that all of your private communications and personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), third parties may unlawfully intercept or access transmissions or private communications, or they may abuse or misuse your personal information that they collect from our Sites. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
              
              ACCESS TO AND CHANGE OF PERSONAL INFORMATION
              
              Upon your request, we will provide you with a copy of your personal information that we maintain in our active databases.  To make this request, you may send an email to support@tgp-solutions.com.
              
              Upon your request, we will change the personal information in your Client or Developer account.  To make a change request, you may send an email to support@tgp-solutions.com. Such personal information will be changed as soon as reasonably possible in accordance with our change policy and applicable law.
              
              Nevertheless, we may elect to not change your information where we are not required to do so by applicable law.  For example, we may refuse to change your personal information related to any Separate Agreement and/or your use of TGP products (including Software).  If you are a party to a Separate Agreement with us, you may change your personal information for purposes of the Separate Agreement only in accordance with the terms of the Separate Agreement.
              
              OBJECTION TO AND RESTRICTION OF USE OF PERSONAL INFORMATION
              
              You may object to our use of your personal information.  To make this objection, you may send an email to support@tgp-solutions.com. We will cease the use of your personal information to which you object as soon as reasonably possible in accordance with our change policy and applicable law.  We may, however, refuse to comply with your objection if applicable law allows us to do so, such as where use of the information is necessary for complying with or enforcing a Separate Agreement. If we refuse to comply with your objection, we will let you know why.
              
              You may also request that we restrict our use of your personal information. To make this request, you may send an email to support@tgp-solutions.com. We will restrict our use of your personal information in compliance with your request as soon as reasonably possible in accordance with our change policy and applicable law.  We may, however, refuse to comply with your request if applicable law allows us to do so, such as where use of the information is necessary for complying with or enforcing a Separate Agreement. If we refuse to comply with your request, we will let you know why.
              
              TRANSFER OF PERSONAL INFORMATION
              
              Our collection and use of your personal information is typically specific to your Client or Developer account, your use of our products and services, and any Separate Agreement you may have with us.  It would be unusual for us to maintain information about you that would be useful for any other purpose, except information that is general in nature.  As a result, if you would like to transfer your personal information that we maintain to another party, please request that we send a copy of your personal information to you, as provided above, and we will send that information to you so you can then transfer it to someone else.
              
              Nevertheless, certain information related to your use of our products and services and any Separate Agreements may be our proprietary and confidential information, and will not be provided to you.  If we refuse to provide you with any such information, we will let you know why.
              
              RETENTION OF PERSONAL INFORMATION
              
              Upon your request, we will deactivate your Client / Developer information from our active databases. To make this request, you may send an e-mail to support@tgp-solutions.com. Such information will be deactivated as soon as reasonably possible in accordance with our deactivation policy and applicable law.
              
              We may retain in our files information you have requested be removed in some circumstances, such as to resolve disputes, troubleshoot problems, and enforce our Terms of Use and the terms of any licenses (including Separate Agreements) you have that permit use of TGP products (including Software). Further, such prior information may never be completely removed from our databases due to technical and legal constraints, including stored “back up” systems. Therefore, you should not expect that all of your personally identifiable information will be completely removed from our databases in response to your request, except as may be required otherwise by applicable law.
              
              PROTECTING YOUR INFORMATION
              
              We use industry standard practices to safeguard the confidentiality of your personal information, including “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ many different security techniques to protect such data from unauthorized access by users inside and outside our company. However, “perfect security” does not exist on the Internet, and we will not be responsible or liable for unauthorized access to or use of any personal information except to the extent required otherwise by applicable law.
              
              CHANGES TO THE PRIVACY POLICY
              
              We reserve the right at any time to add to, change, update, or modify this Privacy Policy simply by posting such addition, change, update, or modification on the Sites and without any other notice to you. Any such addition, change, update, or modification will be effective immediately upon posting on the Sites. It is your responsibility to review this Privacy Policy from time to time to ensure that you continue to agree with all of its terms. If you do not agree with any such additions, updates, modifications or changes, please notify us of your disagreement. Your sole recourse related to such change, however, is to request that we deactivate your Client / Developer account. We may, but we are not required, to notify Clients and Developers of changes to this Privacy Policy by email at their registered email addresses.
              
              CONTACTING TGP
              
              If you have questions about our Privacy Policy, please contact us by e-mail at support@tgp-solutions.com.
              
              EFFECTIVE DATE
              
              This Privacy Policy is effective as of January 1, 2019, and supersedes all prior versions of this Privacy Policy.