Privacy Policy
Introduction
Tom Sheehan, Inc. operates the websites known as “tomsheehan.com” and “19north.com.” This Notice describes Tom Sheehan, Inc.’s privacy practices for information collected on the websites it operates. This Notice also applies to Tom Sheehan, Inc.’s affiliates’ websites that link to this Notice. For simplicity, both tomsheehan.com and 19north.com, along with any affiliate websites, are simply referred to as “the websites” in this Notice.
Tom Sheehan, Inc. supports the right to privacy, including the rights of individuals to control the dissemination and use of personal data that describes them. Tom Sheehan, Inc. is committed to protecting personal data of the users of our websites and utilizes technical and organization measures to protect your data. Tom Sheehan, Inc. supports and complies with domestic and international laws and regulations that seek to protect the privacy rights of such individuals.
This websites is owned and operated by Tom Sheehan, Inc., with principal business offices in Wyomissing, PA 19610 USA. Other websites subject to this Notice may be owned and operated by an affiliate company which is under the control of Tom Sheehan, Inc.. From a data privacy perspective, this means that Tom Sheehan, Inc. is data controller and data collector. Tom Sheehan, Inc.’s Data Protection Officer can be reached by mail at:
Tom Sheehan, Inc.
PO Box 5873
Wyomissing, PA 19610
Data Collection
When visiting our websites, you are not required to provide any personal data. Tom Sheehan, Inc. relies on consent or other lawful principles established for data collection under applicable laws. Therefore, you have the option to abstain from providing personal data when visiting publicly available portions of the websites. However, when registering for an event, subscribing to receive Tom Sheehan, Inc.’s marketing or educational materials or when purchasing or using Tom Sheehan, Inc.’s products or services or in other circumstances, you may be required to provide some or all of the personal data listed below. If you have provided Tom Sheehan, Inc. with your personal data, you have the rights described below in the Data Subject Rights section below.
Tom Sheehan, Inc. collects additional non-personal data as described in the subsequent section of this Notice (Additional Data Collection Activities).
Any data collected may be used in Tom Sheehan, Inc.’s business to provide you the products we offer and to aid in Tom Sheehan, Inc.’s communications efforts and may result in you being contacted by Tom Sheehan, Inc.. In some cases, contact information may be required for Tom Sheehan, Inc. to create an account, enable delivery of materials requested on the websites or to otherwise communicate with you. This may include: providing requested information, making responses to inquiries, registration for Tom Sheehan, Inc. events, and distributions for marketing purposes. You may also be able to register for Tom Sheehan, Inc. services through the websites.
For the purposes mentioned above, Tom Sheehan, Inc. may collect the following personal data about you:
- Full name
- Address
- Mailing Address
- Telephone number
- Email address
To facilitate its communications efforts, Tom Sheehan, Inc. may combine the personal data you provide with information that is not collected directly from you. Data not provided directly by you may be supplied by Tom Sheehan, Inc.’s vendors that support its communications and business efforts. Tom Sheehan, Inc. uses automated processing within its internal systems to optimize its communications activities. You may lodge a complaint with Tom Sheehan, Inc. regarding automated processing by submitting it to Tom Sheehan, Inc. using the contact information provided in the introduction to this policy.
We will retain your personal information as needed to fulfill the purposes for which it was collected. Personal data collected under this Notice is retained as long as you continue to interact with Tom Sheehan, Inc., or we have a legitimate business interest to retain your data.
Additional Data Collection Activities (Automatic Information)
Tom Sheehan, Inc. automatically receives and records information about the use of the websites either directly or through third party tracking utility providers. This may include cookies, IP addresses, your browser type, operating system version, language settings, which locally installed Tom Sheehan, Inc. applications you use (if any) and how you use them, the web page you were visiting immediately prior to visiting our websites, pages of our websites that you visited, the time spent on those pages, information you searched for on our websites, access times and dates, and other statistics. This data is not combined with your personal data collected directly from you.
Tom Sheehan, Inc. utilizes cookies on its websites. Tom Sheehan, Inc. uses IP addresses to help diagnose problems and to administer the Tom Sheehan, Inc. websites. When you visit our Websites, we recognize only your domain name and not your e-mail address. We will see your e-mail address only if you provide it or send us an e-mail message. Tom Sheehan, Inc. does not ask you for, access or track any location-based information from your device. If Tom Sheehan, Inc. wishes to do so in the future to enhance our websites, Tom Sheehan, Inc. will specifically ask your permission.
The collection of personal data is not required for accessing the websites; however, Tom Sheehan, Inc. collects the additional data for the maintenance and optimization of its websites.
Data Processing
Tom Sheehan, Inc. utilizes vendors to support the operation of Tom Sheehan, Inc.’s business and for communications that may receive the data collected under this notice, and these vendors are data processors. However, any such processing is limited to facilitating Tom Sheehan, Inc.’s own activities. Tom Sheehan, Inc. does not share, sell or rent your personal information to any third parties for their promotional purposes.
Additionally, data processors utilized by Tom Sheehan, Inc. are subjected to Tom Sheehan, Inc.’s due diligence process and required to make contractual assurances that they will take adequate precautions to protect your data. Tom Sheehan, Inc. will require such service providers to adopt adequate technical and organizational security measures to ensure the processing of personal data only as instructed by Tom Sheehan, Inc. and for no other purposes.
Additional Transfers
Tom Sheehan, Inc. may share personal information with its affiliates and with vendors working on our behalf as necessary to complete your requests and to provide you Tom Sheehan, Inc. products and services. We may also share data when required by law or to respond to legal process. Tom Sheehan, Inc., its affiliates, and/or the vendors may be located in countries that are not considered to provide an adequate level of data protection as established by the European Data Protection Directive (95/46/EG) or the General Data Protection Regulation ((EU) 2016/679) (GDPR), including the United States. Where required under applicable law, Tom Sheehan, Inc. will implement appropriate measures to secure the data transfers in accordance with applicable data protection laws. Such measure may include use of the Model Clauses or the Privacy Shield Framework.
Tom Sheehan, Inc. has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Tom Sheehan, Inc. remains liable under the Privacy Shield Principles if an agent processes personal data covered by this Notice in a manner inconsistent with the principles, except where Tom Sheehan, Inc. is not responsible for the event giving rise to the damage.
In certain situations, Tom Sheehan, Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Privacy Shield
Tom Sheehan, Inc. complies with the EU-U.S. Privacy Shield Framework and 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 Union or Switzerland to the United States. Tom Sheehan, Inc. has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield site.
The U.S. Federal Trade Commission has jurisdiction over Tom Sheehan, Inc.’s compliance with the Privacy Shield.
Rights you may have under Privacy Shield or applicable regulation, such as the General Data Protection Regulation (GDPR), are described below.
Data Subject Rights
Everyone
You may request from Tom Sheehan, Inc. access to, correction of, blocking of and/or deletion of your personal data in line with applicable data protection law. You may also withdraw your consent for Tom Sheehan, Inc. to process your personal data.
Privacy Shield
In compliance with the Privacy Shield Principles, Tom Sheehan, Inc. commits to resolve complaints about our collection or use of your personal information. European Union residents with inquiries or complaints regarding our Privacy Shield policy should direct any such request and any other questions you may have with regard to the Privacy Shield Principles to Tom Sheehan, Inc.’s Data Protection Officer, whose contact information is listed in the introduction to this Notice.
Tom Sheehan, Inc. commits to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner, as applicable, and comply with the advice given by the panel and Commissioner, as applicable, with regard to human resources data transferred from the EU or Switzerland, as applicable, in the context of the employment relationship.
Tom Sheehan, Inc. has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States, with a global presence. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain circumstances you may invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For more information please visit the U.S. Department of Commerce’s Privacy Shield Site.
GDPR
Data Subjects covered by the GDPR are afforded additional rights including:
- The Right to be Forgotten: you have the right to request the erasure of the personal data submitted to Tom Sheehan, Inc.; this means you can request Tom Sheehan, Inc. restrict your data from any further processing, and have your data deleted if possible.
- Complaints may also be submitted to the applicable supervisory authority in the European Economic Area, which includes the data protection authority in your locality (for example, in the U.K., the supervisory authority would be the Information Commissioner’s Office).
Children’s Privacy
Tom Sheehan, Inc. encourages parents and guardians to take an active role in their children's online activities. Our products and services are not specifically aimed at people under 18 and Tom Sheehan, Inc. does not knowingly collect personal information from children without appropriate parental or guardian consent. If you believe that we may have collected personal information from someone under the age of 13 (or the applicable age of consent) without proper consent, please let us know using the methods described in this Notice.
Tom Sheehan, Inc. Residents, Businesses and Customers
Tom Sheehan, Inc. may also collect personal data from users as required to provide support and delivery of Tom Sheehan, Inc. products and services.
A user’s use of Tom Sheehan, Inc.’s or an affiliate’s products and services is governed by the terms of the contract between Tom Sheehan, Inc. or an affiliate and the user.
Updates to this Privacy Notice
Tom Sheehan, Inc. may update this Privacy Notice from time to time. If we modify this Privacy Notice, we will post the revised version here. We may also provide notification of material changes by other means such as posting a notice on our websites.
Revised: August 1, 2025
