Website Privacy Policy

Introduction

Newco LLC, doing business as Telecom Partners Group (“TPG,” “we,” “us,” or “our”), respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, store, disclose, and safeguard personal information when you visit www.tpgllp.com (the “Website”) or otherwise engage with our research, advisory, and related services.

By using the Website or our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Website or provide us with personal information.

Who We Are

Telecom Partners Group is an independent research and advisory firm focused on the global telecommunications sector. Newco LLC is a Florida limited liability company and is the entity responsible (the “controller”) for personal information collected through the Website. Our contact business address is 42 Broadway, New York, NY 10004.

For questions about this Privacy Policy or to exercise any of the rights described below, please contact us using the details in the “Contact Us” section at the end of this policy.

Scope of This Policy

This Privacy Policy applies to personal information we collect through the Website, through direct communications with you (including email and telephone), and in the course of providing our research and advisory services. It does not apply to third-party websites, applications, or services that may be linked from the Website; we encourage you to review the privacy notices of any third party before providing them with personal information.

Updates to This Policy

We review this Privacy Policy periodically and may update it from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will post the revised policy on the Website and update the “Effective Date” above. Please keep the personal information you provide to us accurate and current, and let us know if anything changes during our relationship with you.

1. Information We Collect

“Personal information” means information that identifies, relates to, or could reasonably be linked with a particular individual. It does not include information that has been de-identified or aggregated so that it can no longer reasonably identify you. Depending on how you interact with us, we may collect the following categories of personal information:

• Identity Information: first name, last name, job title, employer, and similar identifiers.
• Contact Information: business address, email address, and telephone number.
• Profile Information: username, password, areas of research interest, preferences, feedback, and survey responses.
• Usage Information: information about how you access and use the Website and our research products and services.
• Technical Information: IP address, login data, browser type and version, time zone setting, operating system, device identifiers, and similar technical information about the devices you use to access the Website.
• Marketing and Communications Information: your preferences for receiving communications from us and our third-party partners.

We may also collect, use, and share aggregated or de-identified information that cannot reasonably be used to identify you. If we combine aggregated information with personal information so that it can identify you, we treat the combined information as personal information under this Privacy Policy.

We do not knowingly collect sensitive personal information such as Social Security numbers, government identifiers, financial account credentials, health information, racial or ethnic origin, religious beliefs, sexual orientation, or biometric data through the Website. Please do not submit such information to us unless specifically requested.

2. How We Collect Personal Information

We collect personal information in the following ways:

• Directly from you: when you request research or advisory services, subscribe to our publications, create an account, complete a form, attend an event, or otherwise communicate with us by mail, email, telephone, or in person.
• Automatically through the Website: when you interact with the Website, we and our service providers may collect technical and usage information using cookies, pixels, log files, and similar technologies.
• From third parties and public sources: including analytics and security providers, business information databases, professional networks, and publicly available sources such as regulatory filings and corporate registries.

3. How We Use Personal Information

We use personal information for legitimate business purposes consistent with the context in which it was collected and applicable law, including to:

• Provide services: deliver the research, advisory, and related services you or your organization have requested.
• Manage our relationship: administer accounts, process requests, respond to inquiries, and communicate with you about our services.
• Operate and improve the Website: maintain, secure, analyze, and improve the Website, our research products, and our client experience.
• Marketing and events: send research updates, newsletters, invitations, and other communications about TPG’s services, where permitted by law and subject to your preferences.
• Compliance and protection: comply with applicable laws and regulations, respond to lawful requests from authorities, enforce our terms, and protect the rights, property, and safety of TPG, our clients, and others.

We generally do not rely on consent as the legal basis for processing your personal information, except for marketing communications where required by law. Where we do rely on consent, you may withdraw it at any time by contacting us.

4. Cookies and Similar Technologies

Cookies are small text files that a website places on your device to recognize it and store certain information. We use cookies and similar technologies to operate the Website, remember your preferences, understand how the Website is used, and facilitate access to our research portal.

You can set your browser to refuse some or all cookies or to alert you when cookies are being used. If you disable cookies, some parts of the Website may not function properly.

We use Google Analytics and similar analytics tools to collect non-identifying information about visitor behavior and Website performance. We do not attempt to identify individual visitors from analytics data.

5. Emails and Other Communications

Emails you send to us, including any attachments, may be monitored and used by us for security and compliance purposes, including monitoring compliance with our internal policies. We may use email monitoring and filtering software. You are responsible for ensuring that any email you send to us is lawful and appropriate. Please do not send us sensitive personal information by unencrypted email.

6. How We Share Personal Information

We do not sell personal information. We may share personal information with the following categories of recipients:

• Affiliates: members of the TPG corporate group that act as joint controllers or processors and that support the delivery of our services.
• Service providers: vendors that provide information technology, hosting, cloud storage, customer relationship management, analytics, security, payment processing, and similar services.
• Professional advisors: lawyers, auditors, bankers, insurers, and other professional advisors who provide legal, accounting, consulting, banking, insurance, and similar services.
• Regulators and authorities: regulators, law enforcement, tax authorities, and courts, where we are required or permitted to do so by applicable law.
• Business transactions: counterparties and their advisors in connection with a sale, merger, financing, reorganization, or similar transaction.

We require third parties that process personal information on our behalf to respect the security of your personal information, treat it in accordance with applicable law, and use it only for specified purposes consistent with our instructions.

7. International Data Transfers

TPG is based in the United States, and personal information we collect is processed and stored in the United States. If you access the Website or provide information to us from outside the United States, please understand that your information may be transferred to, stored, and processed in the United States and other countries where data protection laws may differ from those in your country of residence.

8. Data Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental loss, unauthorized access, disclosure, alteration, or destruction. We limit access to personal information to employees, contractors, and third parties who have a business need to know.

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

9. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide our services, comply with legal, regulatory, tax, accounting, or reporting obligations, resolve disputes, and enforce our agreements.

10. Your Rights and Choices

Depending on your jurisdiction and subject to applicable exceptions, you may have the right to:

• Access: request confirmation of whether we process personal information about you and obtain a copy.
• Correction: request that we correct inaccurate or incomplete personal information.
• Deletion: request that we delete personal information we hold about you.
• Opt out of marketing: unsubscribe from marketing communications at any time.
• Withdraw consent: where we rely on your consent, withdraw that consent at any time.

11. Children’s Privacy

The Website and our services are intended for business and professional users and are not directed to children under the age of 18. We do not knowingly collect personal information from children under 18.

12. Third-Party Links

The Website may contain links to third-party websites, plug-ins, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control those third-party services.

13. Governing Law

This Privacy Policy and any disputes arising out of or relating to it are governed by the laws of the State of Florida, without regard to its conflict-of-laws principles, except to the extent superseded by applicable U.S. federal law.