Revised: August 18, 2020
Thomas Publishing LLC, including its subsidiaries and affiliates identified below (collectively, “Thomas”, “we” or “us”) respects the privacy of its customers, business partners, and website visitors (collectively “you”). The Thomas Privacy Statement (the “Privacy Statement”) describes the information that we collect, how we obtain the information, and how we may use or disclose that information. This Privacy Statement also describes the measures we take to protect the security of the information and how individuals can contact us about our privacy practices.
Thomas’ U.S. subsidiaries that also adhere to the Privacy Shield Principles include:
Thomas Publishing Company
Thomas Publishing Company, LLC
Thomas Industrial Network Inc.
Thomas Marketing Services, Inc.
Thomas International Publishing Company Inc.
This Privacy Statement covers our privacy practices with respect to the collection, use, and disclosure of personal information obtained through:
- Interaction with all Thomas website properties. In addition to its websites, Thomas provides web-based tools which require individuals to log-in to retrieve data or to update product information. These web-based tools and the Thomas website properties, collectively, are referred to as the Thomas Websites (the “Thomas Websites”).
- Product data management tools and services which include access to CAD and BIM models, product configurators and e-commerce capability, (collectively, “Thomas Product Data Solutions”).
- Marketing services provided to Customers including but not limited to website design & development and inbound marketing services, (collectively, “Thomas Marketing Services”).
- Tracking services provided to Customers including but not limited to website tracking services and call tracking services, (collectively, “Thomas Tracking Services”)
In this Privacy Statement, the Thomas Websites, Thomas Product Data Solutions and Thomas Marketing Services and Thomas Tracking Services are collectively referred to as the “Thomas Service” or “Thomas Services.”
You should review this Privacy Statement carefully, because if you do not agree with our practices, you should not use the Thomas Services. By using the Thomas Services, you accept and agree to our privacy practices.
For the purposes of this Privacy Statement, where not otherwise defined, the following terms have the meanings set forth:
“Customer” means any entity that purchases Thomas Product Data Solutions or Thomas Marketing Services from Thomas.
“Providers” means third parties that advertise on Thomas Websites or provide services, features or information in connection with Thomas Websites.
“Suppliers” means companies that are a part of Thomas' database of companies.
How We Collect Information
As further described below, we collect information from visitors to the Thomas Websites and users of the Thomas Services from several sources:
We collect information you provide to us when you:
- register for a Thomas Website;
- fill out forms on a Thomas Website;
- submit data and content via a Thomas Website, participate in bulletin boards, engage in a chat, post a comment, participate in forums or other interactive features of a Thomas Website or request further information or services from us, one of our Customers or other Suppliers listed on the site;
- enter a contest or promotion we sponsor;
- report a problem with a Thomas Website;
- contact us;
- complete our surveys; or
- subscribe to our email newsletters.
We collect information from third parties as follows:
Thomas may collect reporting and analytics information from third parties in connection with your use of the Services. We automatically collect information as you navigate through the Thomas Websites.
Thomas collects personal information on behalf of our Customers from visitors or users who:
- engage in e-commerce transactions with Customers via the Thomas Services;
- submit informational requests and requests for pricing or quotations from Customers.
- submit forms that may be required to download CAD or BIM sales drawings or other product information requests from Customers.
- access Customer websites that use Thomas Tracking Services
Customers, not Thomas, are obligated to obtain consent from users to collect personal information for these purposes.
Information We Collect
We collect personal information including, without limitation, company name and address, mailing address, email address, IP address and telephone number.
We collect details about your website visits, including, but not limited to, your IP address, usage patterns, traffic data, location data, logs and other communication data and the resources that you access, as well as information about your computer and internet connection, including your operating system and browser type.
Via persistent cookies, which are data files that remain on your computer for future visits until deleted, we may track your behavior at other websites, including what sites you visit and how long you spend there.
In addition to the foregoing, Thomas may collect information on behalf of Customers who have provided forms residing within the Thomas Services, or Customers who have implemented a Thomas Tracking Service, namely
- Company name and address.
- User contact information including, first name, last name, phone number and email address.
- Payment information (credit/debit card information) in connection with an ecommerce transaction.
- Informational requests and requests for pricing or quotes.
- Information about the user’s movements as they navigate throughout the Thomas Services.
How We Use Information Collected
We use information that we collect about visitors to the Thomas Services for the following purposes:
- To present Thomas Websites and Customer websites and catalogs and their contents in a suitable and effective manner for you and for your computer or mobile device.
- To diagnose and resolve technical problems with a Thomas Website and Customer websites and catalogs.
- To improve Thomas Websites and Customer websites and catalogs.
- To provide you with information, products or services that you request from us or our Customers.
- To provide usage reports to Customers who advertise or provide other services on Thomas Websites.
- To provide reporting to Customers who provide information, applications and other services.
- To carry out our obligations and enforce our rights arising from any contracts entered into between Thomas and our Customers, including without limitation, Thomas Website Terms and Conditions.
- To notify you about changes to a Thomas Service or obtain any required consent.
- To allow you to participate in interactive features of a Thomas Website and Customers’ websites and catalogs, when you choose to do so.
- For industry analysis, benchmarking, analytics, marketing, and other business purposes.
- To track your browsing behavior, such as the pages you visited over time.
- To improve your content experience as a newsletter subscriber.
- To improve your Thomas Website experience.
For example, Thomas uses a third party for reporting and analytics to measure the effectiveness of our Thomas Websites, marketing efforts for the Thomas Websites (for example, the effectiveness of email promotions) and to identify areas for improvement.
Cookies and Other Forms of Automated Collection
We use “cookies” to help us improve the Thomas Websites. A cookie is a small piece of data sent from a website and stored on a visitor’s computer by the visitor’s web browser. We use session cookies while you are visiting to obtain information about your general Internet usage and to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Thomas Websites.
- Speed up your searches.
- Authenticate your access to various areas of a Thomas Website.
- Recognize you when you return to a Thomas Website.
- Track when you respond to surveys.
- Provide a consistent website look and feel.
- Capture feedback from site users.
- Connect via social media applications.
- Conduct site testing.
- Provide analytics services about the use of the Thomas Websites.
- Authenticate a user’s access to the Service.
- Track session state in the Service.
- Recognize the user when returning to the Service.
We use third-party ad servers or ad networks, to serve advertisements within and after you visit Thomas Websites. These companies can also send their own cookies. Please note that if an advertiser asks us to show an advertisement to a certain audience or audience segment and you respond to that ad, the advertiser or ad-server may conclude that you fit the description of the audience they are trying to reach. We only authorize our third-party ad servers to employ anonymous cookies for ad delivery and anonymous targeting. These third-party ad servers do not collect, nor do we give them access, to any personally identifying information about you.
Analytics and Interest-Based Advertising
Certain companies may participate in the Digital Advertising Alliance ("DAA") AdChoices Program and may display an Advertising Option Icon for interest-based ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program at http://www.youradchoices.com/. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt-out of certain targeted advertising delivered by NAI members' ad networks. To learn more about opting out of targeted advertising or to use the NAI tool, visit http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt-out of certain kinds of targeted advertising, you will continue to receive non-targeted ads. We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
Sharing of Information We Collect
As set forth more fully above, we collect certain data when you use the Thomas Services. We do not share, sell, rent or trade personal information collected through the Thomas Services with third parties for their promotional purposes except as expressly set forth herein, or with your explicit consent.
We may disclose personal information that you provide to us via the Thomas Services to our subsidiaries and affiliates (including those located outside the European Economic Area and Switzerland) as well as to the following third parties under certain conditions:
- Contractors, business partners and service providers we use to support our business or who provide services on our behalf. Personal information is shared only to the extent necessary for the third party to provide specific services or functions. These third parties (and any subcontractors) are subject to strict data processing requirements and are restricted from utilizing, sharing or retaining your personal information for any other purpose.
- A buyer or acquirer in the event of merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation). In such case personal information held by us about our website visitors will be among the assets transferred.
- Our Customers when we provide you with their products and services you have requested.
- Customers to enable them to provide their website users with information, products or services that such users request.
- If you ask us to contact you about goods and services that may be of interest to you, we may use your personal information or permit selected third parties to use your personal information to provide you with such services.
We may also disclose your personal information to the forgoing third parties or others:
- To facilitate communications with you or between you and the companies that appear on the Thomas Websites or newsletters.
- To comply with any court order or other legal obligation.
- In response to lawful requests by public authorities, government, law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (such as subpoena requests) or to meet national security or law enforcement requirements. To the extent we are legally permitted to do so, we will take reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of legal process.
- To enforce or apply our Thomas Website Terms and Conditions or terms of any other agreement, including agreement between Customer and Thomas pursuant to which the Customer purchased access to the Service.
- To protect the rights, property, or safety of Thomas, our Customers, and our Customer’s website visitors or others.
- To prevent or stop activity we consider to be illegal or unethical.
Solely with regard to the Thomas Websites, we aggregate information we collect to provide usage reports to Customers who advertise or provide other services on Thomas Websites.
Accountability for Onward Transfer of Personal Information
Thomas transfers personal data to third parties acting as agents of Thomas. Thomas will only transfers personal information to third parties for limited and specified purposes and has determined that the agent is able to provide at least the same level of privacy protection as is required by the Privacy Shield Principles. Thomas ensures that the agent can effectively processes the personal information transferred by Thomas in a manner consistent with Thomas’s obligations under the Privacy Shield Principles. We also require agents to notify us if they can no longer meet their obligation to provide the same level of protection as is required by the Privacy Shield Principles. Thomas, after receiving such notice will take reasonable and appropriate steps to stop and remediate unauthorized processing of personal information. Thomas can provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Federal Trade Commission upon request.
Thomas remains liable if its agent processes personal data in a manner inconsistent with the Privacy Shield principles, unless Thomas proves that it is not responsible for the event giving rise to the damage.
Communicating With Suppliers and Providers
When you use the communication features and software applications on Thomas Websites to initiate contact with Suppliers or Providers, you may be asked to supply personal information, including one or more of the following: name, telephone number, fax number, postal address and email address, required by these companies to respond to your request to contact you, depending on how you wish the Supplier or Provider to respond to your request. We will only forward a Supplier or Provider the information you provide.
If you choose to call a phone number listed on the Thomas Websites for a Supplier or Provider, your phone contact information, including such information as your phone number, name and location, may be collected and provided to the Supplier or Provider. Additionally, the phone call may be monitored or recorded if a recorded message or other notification is provided at the beginning of the call to this effect, and the recording will be made available to the Supplier or Provider. Thomas and its affiliates, agents, contractors or service providers may also monitor, store, review and access such information and call recordings and use them in connection with the provision of services to Suppliers or Providers for business and marketing purposes.
Additionally, many Suppliers or Providers may make certain services, information and software applications, such as CAD drawings or white papers, available to the users of Thomas Services free of charge. Some of these Suppliers or Providers may require that you provide your contact and personal information in exchange for access to these services, information and applications. If you do not provide the required information, you will not be able to access these services, information and applications. Once information has been provided to a Supplier or Provider, it is out of the control of Thomas and subject to the policies of that Supplier or Provider.
Public Forums and Comments
Your contributions in public forums, including comment threads, are posted on and transmitted to other visitors of the Thomas Websites at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other visitors of the Thomas Websites with whom you may choose to share your contributions. Therefore, we cannot and do not guarantee that your contributions will not be viewed by unauthorized persons. We are not responsible for circumvention of any privacy settings or security measures contained on the Thomas Websites. You understand and acknowledge that, even after removal, copies of your contributions may remain viewable in cached and archived pages, or might have been copied or stored by other websites. Proper access and use of information provided on the Thomas Websites, including your contributions, is governed by the Thomas Website Terms and Conditions and known or suspected violations should be reported to our Privacy Officer via email at email@example.com. We recommend that you do not share personal information in your contributions.
International Transfer of Data
Thomas may store and process any information collected in connection with the Thomas Services in any country where we have facilities or in which we engage service providers. A list of Thomas’ global offices is provided below. By using Thomas Services, you consent to the collection, storage, transfer and processing of information outside of your country of residence, including in the United States.
Thomas Publishing Company
5 Penn Plaza
New York, NY 10001
Praha 8 - Liben
Transfers of Personal Data
Thomas complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Economic Area and Switzerland to the United States. Thomas has certified to the Department of Commerce that it adheres to Privacy Shield Principles. To learn more about the Privacy Shield Framework(s) and the scope of Thomas’ participation, please visit the Department of Commerce’s website, located at https://www.privacyshield.gov/. With respect to personal information received or transferred pursuant to the Privacy Shield Framework(s), Thomas is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. Thomas annually certifies its adherence to the Privacy Shield Principles of notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability. All U.S. entities and subsidiaries listed in our Privacy Shield certification record also adhere to the Privacy Shield Principles.
Data Integrity and Purpose Limitation
Thomas limits collection of personal information to the information that is relevant for the purposes of processing and we will not process such personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you. To the extent necessary for those purposes, we will also take reasonable steps to ensure that personal information is reliable for its intended use, accurate, complete and current.
Thomas maintains reasonable and appropriate measures to protect the personal information obtained through the Service from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Accessing and Correcting Your Personal Information
You may send us an email at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us in connection with the Website. We will make reasonable efforts to respond to such requests, but reserve the right to enforce reasonable limits in cases where the legitimate rights of persons other than the individual would be violated or where the burden or cost of providing access would be disproportionate to the risks to the individual's privacy.
Customer End-User Data
Communication Preferences and Choices
We provide certain choices regarding the information website visitors provide to us. We have created mechanisms to provide you with the following control over your information when using the Thomas Services. If you no longer wish to have your email address used for promotional purposes by Thomas, you may withdraw consent at any time by clicking on the “unsubscribe” link located in the emails sent by Thomas or by contacting us at: email@example.com, or via your user preference settings.
Third Party Websites and Applications
Thomas Websites may link to websites that are not owned or controlled by Thomas. As such, this Privacy Statement does not apply to information collected on any third-party site or by any third-party application that may link to or be accessible from Thomas Websites. In addition, Customers and other third parties, including our business partners and consultants, may develop applications or provide services to you or other third parties using our Service. This Privacy Statement does not apply to information collected by Customers, our business partners and other third parties or third-party applications or services, even if this information is collected using Thomas Services.
Changes to Our Privacy Statement
Thomas reserves the right to update or change this Privacy Statement from time to time. If we make material changes to this Privacy Statement, we will notify you through an appropriate online notice (and obtain your consent where required by applicable law). Your continued use of the Website or Service is deemed to be acceptance of any updates or changes we make to this Privacy Statement and as such, we ask that you review the Privacy Statement periodically for any updates or changes that we may have made.
To ask questions or comment about this Privacy Statement and our privacy practices or if you need to update, change or remove your information, contact us at: firstname.lastname@example.org, or
Thomas Publishing LLC
5 Penn Plaza
New York, NY 10001
Independent Recourse Mechanism
In compliance with the Privacy Shield Principles, Thomas commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Thomas at email@example.com.
Thomas has further committed to refer unresolved Privacy Shield complaints to ICDR/AAA, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit ICDR/AAA complaint link http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of ICDR/AAA are provided at no cost to you.
PRIVACY RIGHTS IN NON-U.S. JURISDICTIONS
Accuracy and Access to Personal Information
EU and Swiss persons may request access to their personal information under this policy to the full extent required by applicable law in the home country of the person making the request. Such persons may request the correction, amendment, or deletion their personal information that is inaccurate or has been processed in violation of the Privacy Shield Principles. Thomas will reasonably fulfill such requests to the extent required by applicable law.
EU and Swiss persons have the right to ask us not to process their personal information for marketing purposes. We will inform you (before collecting your information) if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by declining to submit your personal information when so informed. You can exercise these rights at any time by contacting us at firstname.lastname@example.org or by sending a letter to the addresses set forth in Contact Information above.
Revocation of Consent
EU and Swiss persons also have the right to revoke their given consent regarding the use and sharing of their personal information. However, it is important to note that in some cases such request may not be immediately or fully executed because it is possible that we have a legal obligation to keep using your personal information. Also, you must consider that for certain purposes, the revocation of consent means that we cannot continue providing the services you requested. You can revoke your consent at any time by contacting us at email@example.com by sending a letter to the addresses set forth Contact Information above.
Accountability and Inquiries
Any EU or Swiss person who is not satisfied with Thomas’s compliance with Privacy Shield may contact Thomas to resolve such complaints at firstname.lastname@example.org or by sending a letter to the addresses set forth Contact Information above. If any EU or Swiss person believes that such a complaint has not been resolved, he or she agrees first to try and settle the dispute by mediation, administered by the International Centre for Dispute Resolution under its Mediation Rules, before resorting to arbitration, litigation, or some other dispute resolution procedure. The rules governing these procedures and information regarding how to file a claim free of charge can be found here: http://go.adr.org/privacyshield.html.
Any EU or Swiss person who remains dissatisfied may contact his or her national Data Protection Authority in the country where the person resides. Thomas has agreed to cooperate and comply with appropriate EU Data Protection Authorities and the Department of Commerce in resolving such disputes. If an EU or Swiss person remains dissatisfied and meets the pre-arbitration requirements of Annex I Part C of the EU – U.S. Privacy Shield Framework, the person may invoke binding arbitration pursuant to procedures in Annex I of the EU – U.S. Privacy Shield Framework Principles found here: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.