Introduction

Thank you for visiting our website www.TCWstrategies.com. This privacy policy tells you how we use personal
information collected at this site. We respect your privacy and are committed to protecting it through our
compliance with this policy. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with or use this website. By downloading, registering with or using this website, you agree to this privacy policy.

This policy describes:

  • The types of information we may collect or that you may provide when you access submit data to, download any content from, or otherwise use our website and web services (the “Website”); and
  • Our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through this Website; or
  • You provide to or is collected by any third party (see “THIRD-PARTY INFORMATION COLLECTION”).

Other websites and apps and these third parties have their own privacy policies, which we encourage you to read before providing information on or through them.

This policy may change from time-to-time (see “CHANGES TO OUR PRIVACY POLICY”). Your continued use of
this Website after we make changes is deemed to be acceptance of those changes, so please check the policy
periodically for updates.

Children under the age of 13

The Website is not intended for children under 13 years of age, and we do not knowingly collect personal
information from children under 13. If we learn we have collected or received personal information from a child
under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the contact information provided at the end of this document.

Information we collect and how we collect it

We collect information from and about users of our Website:

  • Directly from you when you provide it to us; and
  • Automatically when you use the Website.

Information you provide to us.

When you download or use this Website, or initiate electronic communications with us through this Website (for example, by submitting the form on our “Contact Us” page), we may ask you to provide information:

  • By which you, personally, or your company may be identified, such as name, postal address, email address or telephone number (“personal information”); or
  • That is about you but individually does not identify you, such as your current location, services provided or sought,or preferences for products, etc.

This information includes:

  • Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Website, subscribing to our services, sharing or posting material, submitting search queries, sending communications to us or to other subscribers or vendors that use the Website, etc. We may also ask you for information when you interact with us, when you complete optional surveys, and when you report a problem with the Website.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Details of transactions you carry out through the Website.
  • Other information you choose to provide, or to authorize us to access, in connection with providing the Website and our services.

We use industry-standard security protocols to protect data, but please be aware that no security measures are
perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic information collection and tracking.

When you download, access and use the Website, it may use technology to automatically collect:

  • Usage Details. When you access and use the Website, we may automatically collect certain details of your access to and use of the Website, including Website traffic data, location of data storage, logs, data shared with the Website when you are not using it, and other communication data and the resources that you access and use on or through the Website.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
  • Location Information. This Website collects real-time information about the location of your device.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or from you.

If you do not want us to collect any of the above information, do not download the Website, or delete it from your device. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”.

Information collection and tracking technologies.

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your device. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of our Website.
  • Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).
  • Hardware and Software APIs. An application programming interface (API) is a piece of software that access or obtains information from other programs or device components. For example, our Website uses an API to request the current coordinates from your device’s GPS unit. In some cases, you must provide authorization before the Website can use certain APIs.

Third-party information collection

When you use the Website or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Advertisers, ad networks and ad servers.
  • Analytics companies.
  • Your mobile device manufacturer.
  • Your mobile service provider.
  • Others.

These third parties may use tracking technologies to collect information about our users. This may include
information about users’ use of this Website and other apps and websites to serve them interest-based (behavioral) advertising. We do not control these third parties’ tracking technologies or how they may be used.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you have any questions about an advertisement, you should contact the responsible advertiser directly. For
information about how you can opt out of receiving targeted advertising from many providers, see “CHOICES
ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”.

How we use your information.

We use information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the Website and its contents, and any other information, products or services that you request from us.
  • Fulfill any other purpose for which you provide it.
  • Give you notices about your account/subscription, including expiration and renewal notices.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including our Master Services Agreement and any agreement for billing and collection.
  • Notify you when updates are available, and of changes to any products/services we offer or provide though it.

The usage information we collect helps us to improve our Website and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you use the Website.

We may use your information to contact you about our services that may be of interest to you, if you provide your information for such purpose. For more information, see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”.

Disclosure of your information.

We may disclose aggregated information about our users and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the assets of our company, TCW Strategies, Inc. (“Company”), whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the Website EULA and terms of sale and services, and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your choices about our collection, use and disclosure of your information.

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

  • Tracking Technologies. You can set your device to refuse all or some cookies, or to alert you when cookies are being sent. You can choose whether or not to allow the Website to collect information through other tracking technologies when your device prompts you to do so. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Website may then be inaccessible or not function properly.
  • Promotion by the Company. If you do not want us to use your contact information to promote our own or third parties’ products or services, you can opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to the contact address provided at the end of this document.
  • Data Retention and Deletion. We retain data collected in connection with your use of the Website for as long as you have an active user account with us, and for a period of two years after your account is deleted or inactivated. Retained data of inactive user accounts is used only for the purposes of bookkeeping and audits, reactivating an account upon request, or data analytics. Personal information will be de-identified before it is aggregated for data analytics. We will stop collecting any data for which you withdraw your consent to collect, but will retain data collected before such withdrawal in accordance with this policy. You can at any time request that we delete retained data by sending us an email stating your request to the contact address provided at the end of this document. Be advised that in some cases, we cannot delete your personal information except by also deleting/deactivating your user account.

If you do not create an account with us, we store your information collected via the Website for thirty (30) days after your last visit, after which we will delete your information, except for information you submit for the purpose of joining our mailing list – you must unsubscribe from the mailing list, after which we will delete your information.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and correcting your personal information.

You can review and change your personal information by logging into the Website and visiting your account profile page. This includes the ability for you to delete your user account from within the Website.

You may also send us an email at the contact address provided at the end of this document to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights.

California Civil Code Section 1798.83 permits users of our Website that are California residents to request certain
information regarding our disclosure of personal information to third parties for their direct marketing purposes. To
make such a request, please send an email to the contact address provided at the end of this document.

Changes to our privacy policy.

We may update our privacy policy from time to time. If we make material changes to how we treat our users’
personal information, we will post the new privacy policy on this page and provide our users with a notice that the privacy policy has been updated.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we
have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting
this privacy policy to check for any changes.

Responsible disclosure policy

TCW Strategies values its customer’s privacy and aims to keep all its data safe and secure. We encourage responsible disclosure of security bugs. If you believe you have discovered a security issue, please report it as quickly as possible.

When sharing your report, please try to be as thorough as possible, providing enough information so that we can recreate your findings. Code samples and/or screen recordings are great for demonstrating your exploit. You should explain how the vulnerability can be used to impact user data or our systems. If you are using automated tools to find vulnerabilities, please be aware that these tools often report false positives.

To send your report, email security@tcwstrategies.com

Upon receiving your report, we will immediately take steps to identify whether the report is a legitimate issue, and follow up on remediation. TCW Strategies does not have a bug bounty program.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us by e-mail: info@tcwstrategies.com