Welcome to TransGuardian, operated by TransGuardian, Inc. and its parent and affiliate corporations and companies and assigns (collectively referred to as "TransGuardian").

All Products and Services of TransGuardian are made available to our clients subject to this Privacy Policy. By using TransGuardian’s Products and Services, you agree, without limitation or qualification, to this Privacy Policy and agree to receive any required legal notices regarding our privacy practices through the continuous posting of a clear and conspicuous link to the current version of this Privacy Policy on the TransGuardian website, which may be revised from time to time. Please note that the collection and use of information also applies if TransGuardian Products and Services are accessed by direct contact with Transguardian staff and not through the website.

TransGuardian takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties.

Please note that TransGuardian subcontracts some services to other companies and websites, and allows the marketing of other websites on the TransGuardian website. Web sites that are linked from TransGuardian sites may have privacy policies which differ from that of TransGuardian. Any partners with whom TransGuardian subcontracts are subject to contractual restrictions on the use of your information which require subcontractors to respect the confidentiality of your information as provided in this Policy.

This TransGuardian Privacy Policy discloses our privacy practices and contains detailed information about the following:

1. With whom does TransGuardian share information that TransGuardian collects, and how is this information used?

A valuable feature of TransGuardian is that TransGuardian is not a participant in the industry as a trader, dealer, manufacturer, or wholesaler. Therefore, with TransGuardian, information about participating businesses can be significantly more confidential and better protected than traditionally. Trading partners who are willing to cooperate may submit credit application information directly to TransGuardian, under TransGuardian’s confidentiality and neutrality, instead of submitting this information to potential competitors in the industry.

Without TransGuardian, each company in the industry wishing to obtain credit with another company in the industry must apply for credit individually with that other company, by disclosing detailed financial information, identifying information about both the company and its principals, often including dates of birth and social security numbers of the company’s principals, and credit references. With TransGuardian, information can be disclosed primarily to TransGuardian, and TransGuardian will keep this information confidential and secure except as provided herein.

A. Public Directory information:

In the course of operating TransGuardian’s various services, TransGuardian will collect basic public directory-type information, such as company name, address, telephone number, key executives or owners, and the like. This directory-type information may be shared publicly in a variety of ways. It may be published in an actual directory of the industry. Also, many of TransGuardian’s functions will involve transactions between two companies. The TransGuardian website will use previously-stored directory information about companies to make it quick and easy for its customers to create or manage transactions between two companies whose directory information is stored in TransGuardian’s systems. Also, identifying information will also be used by TransGuardian’s customers to check whether a potential trading partner is listed in watch lists or warning lists for anti-money-laundering (AML), denied party, and anti-terrorism laws under the USA PATRIOT Act or the Bank Secrecy Act which is enforced by the IRS.

B. Identifying Information:

Consistent with the “know your customer” requirements of the USA PATRIOT Act and Bank Secrecy Act, and to enable TransGuardian to collect unpaid accounts, TransGuardian will collect additional identifying information about companies and principals such as date of birth or social security numbers, to distinguish different persons with the same names. This information will NOT be shared with anyone other than the company or person that the information describes and will be used by TransGuardian in providing its services, including to correctly identify a company or person notwithstanding the existence of persons with the same or similar names.

Pursuant to section 352 of the USA PATRIOT Act, the U.S. Department of the Treasury and the Securities and Exchange Commission require TransGuardian to obtain, verify, and record the following information for each investor in the TransGuardian Money Market Fund.

• Name
• Address
• Date of Birth (for Individuals)
• Tax Identification Number (social security number for individuals or employer identification number for businesses)

C. Historical Experiences with TransGuardian:

A company’s history of activity with TransGuardian, including whether a company is a member and whether a company has unpaid bills owed to TransGuardian and a company’s claim history, may be stored and used for evaluating that company as a potential trading partner. This information will not be shared with any other partner, except to the extent that TransGuardian may be required to provide a company an opportunity to review and correct information about itself.

D. Credit Bureau Reports:

For several services, TransGuardian will access and rely upon credit bureau reports from recognized credit bureaus. This information will not be shared with anyone other than the company or person that the information describes, and will be used by TransGuardian in providing its services including in analysis. The company or person that the information describes has a right to see all such credit bureau reports, directly from the credit bureau, and TransGuardian strongly encourages all parties to review such information and to correct this information to increase the accuracy of trade decisions involving such credit bureau information. The credit bureaus already have systems in places and legal obligations to allow review and challenges to inaccurate information. TransGuardian will be pleased to assist any party to accessing this information and to correct such information with the credit bureaus if desired.

E. Financial Information:

In the course of delivering several of TransGuardian’s services, TransGuardian may collect typical credit application information from and about companies in the industry and will use this information to make recommendations about the risks of TransGuardian’s clients trading with such other companies and will set prices for insurance and/or risk coverage according to those evaluations. To the extent that this information involves financial information about a company, it will be collected by voluntary submission of that information from the company directly to TransGuardian or to TransGuardian’s client. Additional information such as years in business and membership in industry associations may be independently confirmed from outside sources. Companies will have the right to review all such information and are strongly encouraged to participate with TransGuardian in ensuring that such information is both complete and accurate. This information will not be shared with anyone other than the company that the information describes, and will be used in TransGuardian providing its services including in analysis. Although TransGuardian may price certain services based on this information and provide recommendations, this underlying information will not be shared with TransGuardian’s clients or any potential competitor in the industry.

F. Credit Card and Payment information:

Many of TransGuardian’s services involve very low prices. TransGuardian’s clients may wish to store credit card information in TransGuardian’s system to allow for convenient, routine payments for TransGuardian services. Said information will be kept confidential and secure.

G. Logs of Your Compliance with Laws:

One of the features of some of TransGuardian’s services is your ability to prove that your company has complied with the requirements of law, such as the USA PATRIOT Act and Bank Secrecy Act, by having TransGuardian retain records that your company checked a potential trading partner against watch lists, appointed a compliance officer, and trained its employees about the anti-money-laundering requirements of the law. To serve you and protect you legally, TransGuardian will keep a log and/or record that you have completed these steps. If you are ever questioned about your compliance with these laws, TransGuardian will provide you with these stored records so that you can prove that you complied with the law (or we will send the records to a government agency on your request).

H. Suspicious Transactions:

Note that TransGuardian may be required to submit information to the proper authorities under anti-money-laundering (AML), denied party, and anti-terrorism laws under the USA PATRIOT Act or the Bank Secrecy Act which is enforced by the IRS.

I. Customer Service Correspondence:

If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from TransGuardian to you. We retain these records in order to measure and improve our customer service and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.

J. Questionnaires, Surveys and Profile Data:

From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users’ interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.

K. Disclosure to Third Parties Other Than Transguardian Customers:

We share information with companies that help us process the transactions you request and protect our customers’ transactions from fraud, such as sharing your credit card number with a service that screens for lost and stolen card numbers. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.

We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity or to conduct investigations of violations of our User Agreement. For example, this means that if we conduct a fraud investigation and conclude that one side has engaged in deceptive practices, we can give that person or entity’s contact information (but not bank account or credit card information) to victims who request it.

We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).

As with any other business, it is possible that TransGuardian in the future could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by TransGuardian, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended as described in Section A above.

We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.

L. Information About You From Third Parties:

In order to protect all our customers against potential fraud, we verify with third parties the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card with TransGuardian, we will use card authorization and fraud screening services to verify that your card information and address match the information that you supplied to Transguardian and that the card has not been reported as lost or stolen.

In some circumstances we will conduct a background check on your business by obtaining information about you and your business from a credit bureau or a business information service such as Dun & Bradstreet. If you incur a debt to TransGuardian, we will generally conduct a credit check on you by obtaining additional information about you from a credit bureau, to the extent permitted by law. TransGuardian, at its sole discretion, also reserves the right periodically to retrieve and review a business and / or consumer credit report for any account and reserves the right to close an account based on information obtained during this credit review process.

M. Your Use of Information and Our Services:

In order to facilitate the transactions between TransGuardian members, our service allows you limited access other users’ contact information. By using TransGuardian services, you agree that, with respect to other users’ personally identifiable information that you obtain through the site or through a TransGuardian-related communication or TransGuardian-facilitated transaction, you will only use this information for: (a) TransGuardian-related communications that are not unsolicited commercial messages, (b) services offered through TransGuardian, and (c) any other purpose that such user expressly agrees to after adequate disclosure of the purpose(s).

In all cases, you must provide users with the opportunity to remove themselves from your database and review any information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personally identifiable information about another TransGuardian user to any third party without our consent and the consent of such other user after adequate disclosure. Note that law enforcement personnel and other rights holders are given different rights with respect to information they access.

N. Spam:

TransGuardian does not tolerate spam. Therefore, without limiting the foregoing, you may not add a TransGuardian user to your mail list (email or physical mail) without their express consent after adequate disclosure, even if said user has previously made a purchase from you. We strictly enforce our Anti-Spam Policy! To report TransGuardian-related spam to Transguardian, please contact us.

O. Marketing Alliances:

TransGuardian will not sell any of your information to any party, with the following exceptions:

• Basic public directory information in the nature of a phone book may be published exclusively to the industry as a simple public directory of company names, address, telephone, contact name, and the like. Such information will only be provided to the industry and not for marketing by any company outside the industry.
• Basic public directory information in the nature of a phone book, and any current association memberships, may be provided to trade associations serving the industry to allow those associations to help you in the industry.

P. Non-member Recipients and Requests:

When a member undertakes a transaction with a company or individual who is not a registered member of TransGuardian, we will retain the information that the member submits to us, including, for example, the other party’s email address and/or name, for the benefit of the member who is attempting to trade with the non-member. Additionally, these non-members have the same rights to access and correct information about themselves as anyone else who uses TransGuardian.

Q. General Statistics:

Statistics about the industry, its participants, and transactions that do not identify individual companies, persons, or transactions, may be compiled at a very general level in which hundreds or thousands of transactions are summarized by a small number of statistics, and may be widely shared for the benefit of the industry and planning for the industry and in the course of providing TransGuardian’s services, such as the number of companies distributed around various geographical locations or similar very general information.

2. Your California Privacy Rights: California Notice of Information-Sharing Disclosure

TransGuardian’s Privacy Policy is to share personal information only with the owner’s informed consent. With your consent, from time-to-time, TransGuardian may provide its business partners with contact details for direct marketing purposes of relevant services, products, and programs. If you no longer wish your information to be shared, please let us know. If you have further inquires regarding Transguardian’s information sharing practices, please let us know. The designated contact for these queries is support@TransGuardian.com.  

A. Where is Personally identifiable information stored and processed?

The information collected by TransGuardian is stored and processed in the United States at secure facilities with state-of-the-art security measures for data security. We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order:

• to provide our services and process your transactions,
• to provide customer service, and
• to improve our products and services.

B. What security measures apply to information that TransGuardian collects?

TransGuardian is committed to handling your information with high standards of information security. The security of your personal information is important to us. When you enter sensitive information such as a credit card number and/or social security number on our registration or order forms, we encrypt that information using secure socket layer technology (SSL).

We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

Your credit card and bank account information are stored only in encrypted form. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes.

The security of your TransGuardian account also relies on your protection of your TransGuardian password. You may not share your TransGuardian password with anyone. Transguardian will never ask you to send your password or other sensitive information to us in an e-mail.

Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with https://www.TransGuardian.com/ should be treated as unauthorized and suspicious and should be reported to TransGuardian immediately. If you do share your TransGuardian password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at www.TransGuardian.com and changing your Profile settings and also contact us right away.

C. What are “cookies” and how does TransGuardian use them?

In addition, TransGuardian’s website may use a “cookie” purely for the accurate operation of TransGuardian’s website, and not for any other purpose. This technology plays an important role in making the Internet work, but there is much confusion among Internet users about what cookies and how they are used.

A cookie is a small text file containing a unique identification number that is transferred from a Web site to the hard drive of your computer so that the website may remember your preference settings and other technical details for the proper operation of the TransGuardian website.

“Cookies” have become controversial because they are thought to collect information on what people do with their computer. Actually, that type of cookie is quite rare. TransGuardian does not use any cookies to store any of your activities. TransGuardian will only use cookies for purely technical details for the operation of the website such as your website “settings” and preferences. For example, cookies can help us determine that only one user is logged on under your registration at a time.

D. What is the opt-out policy with TransGuardian?

TransGuardian will not be able to operate without collecting the information and using it as described above. Therefore, if you do not want to share such information with TransGuardian, you will not be able to use TransGuardian’s services.

E. How does TransGuardian comply with the Children’s Online Privacy Protection Act (COPPA)?

The Children’s Online Privacy Protection Act (COPPA) of 1998 provides safeguards to protect children who use the Internet by regulating the online collection of personal information from children under the age of 13. Because of these safeguards, children under 18 are not able to access TransGuardian’s Products and Services on TransGuardian.

F. How can I review and make changes to my personal information?

You can obtain a copy of and request that we correct errors in your Personal Information by emailing us at support@TransGuardian.com. If you would like to deactivate or terminate your account you can also contact Customer Service.

G. Contact Us.

Questions regarding this statement should be directed to:
TransGuardian Privacy Site Coordinator
Transguardian, Inc.
2085 Altadena Avenue
Altadena, CA 91001
Telephone (866) 699-3671
Fax (866) 775-4422

H. Updates

TransGuardian may update this policy from time to time so please check back periodically.