Privacy Policy

Last updated: September 1st, 2021

Your privacy is important to us.

It is THF Group of Companies’ policy to respect your privacy regarding any information we may collect from you across our websites, https://thfgoc.com/ and https://fhginterests.com, and other sites we own and operate. Our commitment to privacy includes being transparent about the nature and extent of that processing and the rights that may be available to you with respect thereto. This “Privacy Policy” describes the privacy practices of THFGOC in connection with our websites. This Privacy Policy also describes the rights and choices available to individuals with respect to their information. THFGOC may provide additional or supplemental privacy policies to individuals for specific interactions at the time THFGOC collects personal information, such as employment interactions. These supplemental privacy policies will govern how we may process the information in the context of the specific interaction.

1. Information we collect

  • Information you provide to us. Personal information you provide to us through our websites or otherwise includes business and personal contact information, such as your first and last name, email and mailing addresses, home phone number, mobile phone number, professional title, employer name, or work address.
  • Content you choose to upload to our websites, such as text, images, audio, and video, along with the metadata associated with the files you upload.
  • Log Data, such as your Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other similar data.
  • Profile information, such as your username and password that you may set to establish an online account with us.
  • Registration Information, such as information that may be related to a service or an account for which you register.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
  • Demographic Information, such as your city, state, country of residence, postal code, gender, and age.
  • Financial information, such as your stated income, financial account number, or payment card information.
  • Government-issued identification numbers, such as a national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license of state ID number), and an image of the relevant identification card.
  • Precise geolocation information, such as when you authorize one of our websites to access your location.
  • Transaction information, such as information about payments to and from you and other details of products or services you have purchased from us such as billing and shipping information.
  • Usage information, such as information about how you use our websites and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of our websites.
  • Marketing information, such as your preferences for receiving communications about our activities, business, and publications, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

  • it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose or we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

3. Collection and use of information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

  • to provide, operate and improve our websites and our products and services;
  • to provide information about our products and services;
  • to establish and maintain your user profile related to our websites;
  • to administer and process payments;
  • to enable security features of our websites, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
  • to communicate with you about our websites, including by sending you announcements, updates, security alerts, and support and administrative messages;
  • to communicate with you about events or transactions in which you participate;
  • to understand your needs and interests, and personalize your experience with our websites and our communications;
  • for research and development of our products, services and transactions
  • to provide support and maintenance for our websites; and
  • to respond to your requests, questions and feedback.

We may use also your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern our websites and our products and services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity. In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

4. Disclosure of personal information to third parties

We may disclose personal information to third party service providers for the purpose of enabling them to provide their services, including (without limitation) affiliates, service providers, partners, professional advisors, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators, or as part of the sale of our business assets or other business transfer. If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

5. International transfers of personal information

The personal information we collect is stored and processed in United States, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

6. Your rights and controlling your personal information

  • Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use our websites and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of our websites or the products and/or services offered on or through it.
  • Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
  • Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our websites or products and services.
  • Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
  • Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
  • Notification of data breaches: We will comply laws applicable to us in respect of any data breach.
  • Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
  • Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including any marketing communications), please contact us using the details below.

7. Cookies

Like many websites, we use cookies and similar technologies to collect additional website usage data and to improve our site and services, but we do not require cookies for many parts of our site and services such as searching and looking at public user profiles. A cookie is a small data file that is transferred to your computer or mobile device. Our websites may use both session cookies and persistent cookies to better understand how you interact with our site and services, to monitor aggregate usage by our users and web traffic routing on our site, and to customize and improve our services. Most Internet browsers automatically accept cookies. If you don’t wish to accept cookies from us, you should instruct your browser to refuse cookies from our websites with the understanding that we may be unable to provide you with some of your desired content and services. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie.

8. Other Sites and Services

Our websites may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

9. Security of Information

The security of your personal information is important to us. We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

10. Limits of our policy

Our websites may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites and cannot accept responsibility or liability for their respective privacy practices.

11. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our websites. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information. If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

12. How to Contact THFGOC with Questions

Any questions regarding this Privacy Policy should be submitted through the “Contact Us” page on our websites.

13. Governing Law

The Privacy Policy shall be governed by, and will be construed under, the laws of the State of Texas, USA, without regard to choice of law principles.