Privacy Policy

Effective date: 08/21/2026
Last updated: 08/21/2026

TGES America Ltd. (“TGES America,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains what personal data we collect through tgesam.com (the “Site”), why we collect it, who we share it with, how long we keep it, and the choices and rights you have.

TGES America Ltd. is a subsidiary of Tokyo Gas Engineering Solutions Corporation (“TGES”). We operate from offices in Houston, Texas and Duncan, South Carolina.

Please read this policy carefully. By using the Site, you agree to it. If you do not agree, please do not use the Site.

1. What this policy covers

This policy applies only to personal data we collect through this Site, including our inquiry forms and our job application form, and to correspondence you send us in response to the Site.

This policy does not cover:

• Customer operational data. Operational, metering, or facility data we process under an energy service agreement or other written contract with a customer. That data is governed by the contract with the customer, not by this policy.
• Employees and contractors. Personal data about our employees and contractors in their employment relationship with us, which is governed by our internal human resources policies. Job applicants are covered by this policy until they are hired.
• Other websites. Websites operated by Tokyo Gas Engineering Solutions Corporation, Tokyo Gas America Ltd., or any other affiliate, and websites of third parties we link to. Those sites publish their own privacy notices, and where they differ from this one, theirs govern their sites and this one governs the Site.

This is a business-to-business website. It does not sell products, take orders or payments, host user accounts, or accept public comments or postings.

2. Information we collect

2.1 Information you give us

Inquiry and consultation forms. When you contact us through the Site, we collect the information you enter, which typically includes your name, company, job title, business email address, business telephone number, the location and type of your facility, information about your energy load or the problem you are trying to solve, and any other content of your message.

Job applications. When you apply for a role, we collect your name and contact details, the resume file you upload, and whatever that file contains, which typically includes work history, education, professional licenses and certifications, and references. We also collect any additional information you choose to provide in the application.

Correspondence. If you email or call us, we keep the correspondence and any information it contains.

2.2 Information collected automatically

Cookies. Cookies are small files stored on your device by your web browser. They let the Site and its forms function, and let us measure how the Site is used. We use first-party cookies and the data they generate, and we permit the limited set of service providers named below to set cookies for the services they perform for us.

Server and security logs. Our hosting and security providers log IP addresses, browser and device type, referring page, pages requested, and date and time stamps. We use these to operate the Site, investigate errors, and protect against abuse.

Google Analytics. We use Google Analytics 4 to understand how the Site is used. It sets cookies (including _ga and _ga_*) and collects information such as pages viewed, time on page, referring source, browser and device characteristics, and approximate location derived from IP address. Google states that for visitors in the European Economic Area, the United Kingdom, and Switzerland, IP addresses are used only to derive coarse location and are then discarded rather than logged or stored. Google Analytics assigns a random identifier to a browser so that repeat visits can be counted as one visitor rather than several. That identifier is specific to this Site. We do not use it to identify you by name, and we do not combine it with information about your activity on other websites.

Cloudflare Turnstile. We use Cloudflare Turnstile to distinguish human visitors from automated bots on our forms. Cloudflare states that Turnstile processes client-side signals including IP address, TLS fingerprint, user agent, and the site key and its associated origin, that these signals are used to detect and block bots, and that Turnstile is not used for advertising or cross-site tracking.

Functional cookies. Our website and form software set cookies necessary for the Site and its forms to work, including preserving form entries and protecting against form abuse.

Other information your browser transmits. When your browser requests a page it transmits information about itself, which may include the user agent, language and encoding settings, screen and window dimensions, the date and time of your visit, and the address of the page you came from.

2.3 What we do not collect, and what we do not do

We do not collect payment card numbers, bank or financial account details, government identifiers, health information, biometric data, or any protected classification characteristic such as race, color, national origin, citizenship, religion, marital status, disability, sex, gender, pregnancy, age, or veteran status. The Site has no facility for you to provide them. If you send any of this to us anyway, we will delete it.

We do not sell personal data. We do not share personal data for targeted, interest-based, or cross-context behavioral advertising. We do not use web beacons, pixel tags, clear GIFs, or advertising tags on the Site to build advertising audiences or retarget you elsewhere. We do not match your browsers or devices to one another, and we do not combine your activity on the Site with your activity on unaffiliated websites. We do not create profiles or inferences about visitors, and we do not use personal data for profiling that produces legal or similarly significant effects.

We do not knowingly collect sensitive personal data through the Site, and we ask that you not submit it. Please also do not submit confidential technical or commercial information through a web form before a confidentiality agreement is in place.

3. Why we use personal data

We use personal data to:

• Respond to your inquiry, assess whether a project is feasible at your site, and prepare and discuss a proposal.
• Manage recruiting, evaluate applications, and communicate with candidates.
• Operate, maintain, and improve the Site, including measuring which content is useful.
• Conduct analysis, auditing, research, and reporting on how the Site performs and which categories of visitors use it.
• Carry out research and surveys that help us understand what visitors need, so we can improve our services and the information we publish.
• Protect the Site, our forms, and our systems against cyberattacks, fraud, and abuse, and prevent the data breaches that could follow from them.
• Send information you request and, where permitted, occasional company or project updates. You can opt out at any time.
• Carry out and enforce our agreements, comply with law, and establish, exercise, or defend legal claims.
• Evaluate or complete a merger, reorganization, financing, or sale of assets, where personal data held by us is among the assets involved.

We will tell you at the point of collection if we intend to use your information for any materially different purpose, and we will ask for your consent where the law requires it.

4. Our legal bases

We process personal data only where we have a legal basis to do so. Depending on the circumstances, we rely on:

• Consent. Where you have given us permission for a stated purpose, including for analytics cookies where consent is required. You may withdraw consent at any time, without affecting processing already carried out.
• Legitimate interests. We have a legitimate interest in operating our business, responding to inquiries, recruiting, understanding how the Site is used, and keeping the Site secure. We use information as described in Section 3, and we take due care that this use does not create a risk to your rights and freedoms.
• Steps before entering a contract. Where processing is necessary to take steps at your request before entering into a contract, or to meet our obligations under one.
• Legal obligation. Where the law requires us to process the information.

5. When we share personal data

We share personal data only as described here:

• Our parent and affiliates. We may share your inquiry or project information with Tokyo Gas Engineering Solutions Corporation and other TGES group entities where they support the engineering, financing, or evaluation of your project, or provide us with operational support for the purposes in Section 3. This involves transferring personal data to Japan. See Section 12.
• Service providers. Website hosting, email, form processing and file storage, analytics, bot protection, applicant tracking, and professional advisers, each acting on our instructions and bound to protect the data. Our analytics provider is Google Analytics and our bot-protection provider is Cloudflare. To ask about any other provider we use, contact us using the details in Section 16.
• Legal and regulatory. Where required by law, court order, subpoena, or regulator, or where we believe disclosure is necessary to protect the rights, property, or safety of TGES America, our customers, or the public.
• Corporate transactions. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to appropriate confidentiality protections.

We may also disclose aggregated or de-identified information that does not identify any individual, without restriction.

We do not disclose personal data to third parties for their own marketing purposes.

6. Cookies and your choices

The Site uses two categories of cookies and similar technologies:

• Strictly necessary, for page delivery, form function, and bot protection. The Site does not work properly without these.
• Analytics, for the Google Analytics measurement described in Section 2.2.

Controlling cookies in your browser. You can set your browser to refuse all cookies, or to tell you when a cookie is being set so you can decide whether to accept it. You can also delete cookies already stored on your device. If you block or delete cookies, parts of the Site may not work correctly, and blocking strictly necessary cookies may prevent forms from submitting.

Opting out of Google Analytics. You can block Google Analytics specifically using Google’s browser opt-out add-on.

Opt-outs are per browser and per device. An opt-out applies only to the browser or device where you set it. You will need to opt out separately on each browser and device you use. If you delete or reset your cookies, change browsers, or use a different device, an opt-out cookie may no longer work and you will have to opt out again.

Marketing email. If we send you company or project updates, every message includes an unsubscribe link. You can also email us using the details in Section 16 and we will remove you.

Global Privacy Control and Do Not Track. We honor the Global Privacy Control (GPC) signal as an opt-out request where applicable law requires it. Because we do not sell personal data and do not use it for targeted advertising, a GPC or Do Not Track signal does not change how we handle your data on this Site.

7. How long we keep personal data

We keep personal data to the minimum extent necessary for the purposes described in this policy, and no longer.

• Inquiries that do not become projects: 24 months from last contact.
• Customer and project contacts: for the term of the relationship and 7 years after, consistent with our contract and tax record retention.
• Job applications: at least one year, as required by federal recordkeeping rules, and generally no longer than 2 years unless you ask us to keep your materials on file for future openings.
• Server and security logs: 12 months.
• Google Analytics data: 14 months.

Where a service provider holds data on our behalf, the retention period depends on the category of data and that provider’s own practices. Our providers are subject to applicable data protection law and retain data only for a period those laws permit.

We may keep personal data longer where it is needed to comply with a legal obligation, resolve a dispute, or establish or enforce our agreements, or where a legal hold or regulatory obligation requires it.

8. Security

We and our service providers use appropriate, commercially reasonable administrative, technical, and physical safeguards intended to protect personal data against loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. These include transport encryption on the Site, access controls, and bot protection on our forms. Google Analytics has been certified to the ISO 27001 information security standard.

No method of transmission or storage over the internet is completely secure. Although we work to protect your personal data, we cannot guarantee absolute security, and any transmission is at your own risk.

9. Your privacy rights

Depending on where you live, you may have some or all of the rights below. We extend the core rights to every visitor, regardless of where you live.

• Know and access. Confirm whether we process personal data about you, learn the categories we collect and the sources, purposes, and recipients involved, and obtain a copy of the specific pieces in a portable format.
• Correct. Have inaccurate personal data corrected.
• Delete. Have personal data we collected about you deleted, subject to legal exceptions.
• Object or restrict. Object to, or ask us to limit, our collection and processing of your personal data.
• Withdraw consent. Revoke any consent you have given us, at any time.
• Opt out. Opt out of the sale of personal data, of processing for targeted advertising, and of profiling with legal or similarly significant effects. As stated in Section 2.3, we do none of these.
• Non-discrimination. Exercise these rights without being denied service or receiving different treatment.

How to make a request. Email info@tgesam.com with the subject line “Privacy Request.” Tell us which right you want to exercise and which information it concerns. You may also write to us at the postal address in Section 16.

Verification. We will take reasonable steps to verify your identity before acting, usually by confirming details you have already given us or by replying to an email address of record. We may decline a request we cannot verify. We may also decline to make a correction where we believe the change would violate a law or legal requirement, or would make the information incorrect.

Authorized agents. An authorized agent may submit a request on your behalf with proof of authorization. We may still contact you to confirm.

Timing. We respond without undue delay and no later than 45 days after receiving a verified request. We may extend that period once by a further 45 days where reasonably necessary, and we will tell you within the first 45 days if we do. For requests under the GDPR or UK GDPR, we respond within one month, extendable by two further months for complex requests.

Appeals. If we decline your request, our response will explain why and how to appeal. To appeal, reply to our decision or email info@tgesam.com with the subject line “Privacy Appeal.” We will respond in writing within 60 days and explain the reasons for our decision.

10. Complaints and judicial remedies

If we deny your appeal, or if you are dissatisfied with how we have handled your personal data, you may submit a complaint to the attorney general for your state.

If you are in the European Economic Area, the United Kingdom, or Switzerland, you may lodge a complaint with the data protection authority where you reside, where you work, or where the alleged infringement took place. You also have the right to an effective judicial remedy in the country of your habitual residence.

11. Additional notice for California residents

This section supplements the rest of this policy and applies only to residents of California. We provide it under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and its regulations (together, the “CPL”). “Personal information” in this section has the meaning given in the CPL. It does not include publicly available information from government records, de-identified or aggregated information, or information excluded from the CPL’s scope.

Categories we collect

In the 12 months before the effective date of this policy, we collected the following categories, from the sources and for the purposes described in Sections 2 and 3, and disclosed them for business purposes to the categories of recipients described in Section 5.

What this means for your rights

We do not sell personal information and do not share personal information for cross-context behavioral advertising, including that of consumers under 16 years of age. Because we do not collect sensitive personal information, the right to limit the use of sensitive personal information does not apply. We do not use personal information to infer characteristics. We do not offer financial incentives in exchange for personal information.

California residents may exercise the rights in Section 9, may appeal as described there, and may designate an authorized agent. We will not discriminate against you for exercising any of them.

Shine the Light

California Civil Code Section 1798.83 allows California residents to request, once a year and free of charge, information about personal information we disclosed to third parties for their own direct marketing purposes in the preceding calendar year. We do not disclose personal information for that purpose. To make a request anyway, contact us using the details in Section 16.

12. Visitors in the European Economic Area, the United Kingdom, and Switzerland

TGES America Ltd. is the controller of personal data collected through the Site. Our legal bases are set out in Section 4.

International transfers. We are in the United States and our parent company is in Japan. Personal data you provide will be transferred to and processed in the United States and may be transferred to Japan. Personal data held by our service providers may be stored on servers outside your country. The European Commission has recognized Japan as providing an adequate level of data protection. For transfers to the United States and to other countries without an adequacy decision, we and our service providers rely on the European Commission’s Standard Contractual Clauses, or the UK International Data Transfer Agreement or Addendum, as applicable. You may request a copy of the relevant safeguards by contacting us.

Additional rights. In addition to the rights in Section 9, you may object to processing based on legitimate interests, request restriction of processing, and withdraw consent at any time without affecting processing already carried out. Your rights to complain and to a judicial remedy are described in Section 10.

Representatives. Tokyo Gas Engineering Solutions Corporation, our parent company, has appointed the following representatives for the European Economic Area and the United Kingdom:

European Economic Area
DP-Dock GmbH, Attn: Tokyo Gas Engineering Solutions
Email: tokyogasengineeringsolutions@gdpr-rep.com
Address: Ballindamm 39, 20095 Hamburg, Germany

United Kingdom
DP Data Protection Services UK Ltd., Attn: Tokyo Gas Engineering Solutions
Email: tokyogasengineeringsolutions@gdpr-rep.com
Address: 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom

For anything concerning this Site, please contact TGES America directly using the details in Section 16.

13. Children

The Site is directed to businesses and professionals and is not intended for children. We do not knowingly collect personal data from anyone under 16. If you are under 16, please do not use the Site or provide any information through it. If we learn that we have collected personal data from a child under 16, we will delete it. If you are a parent or guardian and believe your child has given us personal data, contact us and we will address it.

14. Third-party links

The Site links to third-party websites, including those of our parent company, our customers, and industry organizations. Those links are provided for your convenience. We do not control those sites, we are not responsible for their content or privacy practices, and we accept no liability for any loss arising from your use of them.

15. Changes to this policy

We may update this policy from time to time. We will post the updated policy with a new “Last updated” date at the top, and where a change is material we will provide a more prominent notice on the Site. We recommend that you review this policy periodically. Your continued use of the Site after we post a change means you accept it.

16. Contact us

Questions, requests, and appeals:

TGES America Ltd.
Attn: Privacy
5373 W Alabama St., Ste. 582, Houston, TX 77056
Email: info@tgesam.com