TOTAL PROPERTY CARE, INC.
PRIVACY POLICY

The privacy of our employees and customers is very important to Total Property Care. It is our intention to collect only the necessary Non-Public Personal Information (“NPI”) in a fair and non-intrusive manner with the consent of its customers and employees. TPC will protect the NPI from intentional distribution to third parties, as much as possible, except as provided for in this policy, for the specific function for which it is collected. This privacy policy is intended to assist you in understanding the types of information TPC may collect, how that information may be used, and if any of the information may be shared.

TPC Is Not A Financial Institution.

TPC does not believe that it is a financial institution. Nonetheless, to the extent that we may provide services prior to billing, we want to make sure that our customers and employees understand TPC's commitment to maintaining their privacy.

What Type Of Information Does TPC Collect?

At times, TPC may collect Non-Public Personal Information from its customers and employees. Non-Public Personal Information ("NPI") may include a name, address, income, social security number, or other information from an application for employment; it may include account numbers, financial institution information, credit histories or credit or debit cards; and it may include email addresses and employment references. This is not intended to be a complete list of NPI that may be collected by TPC, but it serves to give you a basic guideline of what NPI may be in TPC's possession. It is not the intention of TPC to collect any sensitive NPI, except to comply with Affirmative Action data requirements and other government reporting information including gender, disabilities and veteran status.

TPC's Web Page.

While TPC maintains a web page, we do not use data collection devices, such as "cookies" on our web pages. Cookies are pieces of information gathered by the host site's hard drive while the individuals use the web site. At this time, TPC does not intend to use cookies to collect NPI from those using it. If you wish to turn off cookies when using your web page browser, you may use an option on your own personal computer to assist you. TPC's web page is not designed or intended to be used for anything other than business purposes and TPC does not knowingly allow anyone under the age of thirteen (13) to provide any personal identifying information.

Collection And Use Of Employee Personal Information.

TPC collects NPI from its employees and applicants for its application and hiring programs, compensation and benefit information, performance appraisals, training, human resource records, affirmative action data, and other employment related purposes, including health benefits and health related information. It is TPC's policy to keep all past and present employee information private from disclosure to third parties who do not have a legitimate reason for access to the NPI. TPC strives to be compliant with federal HIPAA regulations and uses health information related to the company's sponsored health care plan, and even then "on a need to know" basis for administration of the benefits.

There are certain business related exceptions to the use of employee NPI, including:

1. Disclosure to third parties with whom TPC has contractual agreements to assist in the administration of company-sponsored benefits. These include verifications of employment with prospective employees, state agencies, financial institutions (only as necessary) and other affirmative action information. Requests of this type are referred to and completed on a confidential basis by management. Generally, health information will only be provided when the request is accompanied by an employee's signed authorization to release information. Any such request will be maintained in the employee's confidential employment record;

2. Disclosure to county, state or federal agencies upon request;

3. Disclosure upon inquiries from third parties with a signed authorization from the employee to release the information, except where other exceptions may apply or as permitted by law.

 

Collection And Use Of Customer Information.

TPC collects customer NPI when the customer contacts TPC directly. Some NPI may be necessary in order to allow TPC to fully address a customer's needs. NPI collected from customers (and prospective customers), may include but is not limited to: name, address, telephone number, facsimile number, email address, tax identification number, and bank account information for Electronic Funds Transfer. TPC generally only discloses NPI to affiliated third parties, including subcontractors, to perform pursuant to the customer's direction or agreement with TPC. The information disclosed is generally limited to the name, address and any other NPI necessary to allow the subcontractor to complete its work.

 

Safeguarding NPI

Generally, TPC restricts access to NPI to employees who need the information to provide the products and services to our customers and those entities noted above. TPC takes all reasonable steps to insure that NPI is accurate, up-to-date, complete, relevant and not misleading, and furthermore takes all reasonable steps to make sure that the information is not disclosed to anyone not entitled to the information.

 

 

Retaining And Storing NPI.

As stated earlier, TPC does not intend to disclose NPI to any third party, except as described in this privacy policy and unless such disclosure is requested and the disclosure is required by law or consented to by the individual. TPC has taken all reasonable steps to prevent the unauthorized use or disclosure of NPI. TPC intends to retain NPI only for so long as necessary to fulfill the purposes for which it was collected and to comply with applicable laws. Your consent to the use of your NPI remains valid after termination of our relationship or completion of our relationship with you.

 

Miscellaneous Information.

TPC in its privacy policy cannot and does not apply to external web pages. At this time, TPC does not endorse or make any representations about third party web sites, the privacy maintained by those web sites or any personal data you choose to give to third parties, which would not be covered by our privacy policy. We encourage you to review the privacy policy of any company's web site before submitting NPI on that web page. Some third parties may choose to share your NPI with other parties, which would be governed by that third party's privacy policy.

TPC believes that it is in compliance with the United States Department of Commerce safe harbor requirements regarding the transfer of personal information, particularly as applies to European Union Companies to the United States . TPC does not believe that it has any information related to international businesses. If so, TPC will comply with all necessary regulations, including the principles of the Safe Harbor compliance on notice, choice, onward transfer, security, data integrity, access and enforcement. Additional information about International Safe Harbor principles and certification of process can be found at www.export.gov/safeharbor .

Contact Information.

You may contact the Privacy Officer to access, correct or delete your Personal Information. If necessary, the Privacy Officer will contact another employee to assist in completing your requested task.

If you have any questions or complaints, please contact the Privacy Officer. The Privacy Officer can be reached by telephone at: (260) 459-1300 or 1-877-872-1199; by Facsimile at: (260) 432-2011; by email at: jonc@fwtpc.com; or by mail at TPC Group, 2801 Lofty Drive, Fort Wayne, IN, 46808, USA. We will address your concern and attempt to resolve any problem.

 

Privacy Policy.

TPC's privacy policy may be ended or modified at any time, without prior notification.