Effective Date
April 7, 2026
This Privacy Policy (“Policy”) describes how Surplus Technology Solutions, a Massachusetts corporation doing business as Tech Recycling Solutions(“Company,” “we,” “us,” or “our”), collects, uses, stores, and protects information about you when you visit our website or use our services. By using our website or services, you consent to the practices described in this Policy.
Massachusetts 201 CMR 17.00 Compliance
We comply with the Massachusetts Standards for the Protection of Personal Information of Residents of the Commonwealth (201 CMR 17.00), which requires businesses that own, license, store, or maintain personal information about Massachusetts residents to implement a comprehensive Written Information Security Program (WISP) and take reasonable steps to protect that information.
1Company Identity
Legal Entity: Surplus Technology Solutions, a corporation organized under the laws of the Commonwealth of Massachusetts.
Trade Name: Tech Recycling Solutions (dba).
Principal Place of Business: 131 Linden Street, Unit 9, Waltham, Massachusetts 02451.
Privacy Contact: info@techrecyclingsolutions.com | (508) 466-6100
2Information We Collect
We collect information in the following categories:
- Name (first and last)
- Business or organization name
- Email address
- Phone number
- Mailing or service address
- Service requests and quote inquiries
- Description of equipment or materials for recycling
- Pickup scheduling details
- Invoice and payment records
- Chain-of-custody and destruction documentation
- IP address and browser type
- Pages visited and time spent on site
- Referring website or search query
- Device type and operating system
- Cookie and session data (see Section 7)
- Emails and messages sent to us
- Phone call records (date, time, duration — not recorded)
- Form submissions from our website
We do not collect Social Security numbers, financial account numbers, driver's license numbers, or other sensitive personal identifiers through our website or standard service intake process unless specifically required for a regulated service and disclosed at the time of collection.
3How We Use Your Information
We use the information we collect for the following purposes:
- To respond to quote requests, service inquiries, and scheduling requests
- To provide, manage, and document our recycling and data destruction services
- To issue Certificates of Data Destruction, recycling certificates, and weight manifests
- To process invoices and manage payment records
- To maintain chain-of-custody records as required by RIOS Certified Recycler certification standards
- To communicate service updates, confirmations, and follow-ups
- To comply with Massachusetts and federal legal obligations
- To improve our website and service offerings based on usage patterns
- To send occasional service-related communications (you may opt out at any time)
We do not sell, rent, or trade your personal information to third parties for marketing purposes.
4Massachusetts 201 CMR 17.00 — Written Information Security Program
In compliance with Massachusetts 201 CMR 17.00, we maintain a Written Information Security Program (WISP) that includes:
- Designation of an employee responsible for maintaining the security program
- Identification and assessment of reasonably foreseeable internal and external risks to personal information
- Implementation of security policies for employees relating to storage, access, and transportation of personal information
- Disciplinary measures for violations of the security program
- Oversight of third-party service providers with access to personal information
- Reasonable restrictions on physical access to records containing personal information
- Regular monitoring and review of the security program
- Documentation of responsive actions taken in connection with any incident involving a breach of security
Technical Safeguards: Our information security measures include secure access controls, encryption of personal information transmitted over public networks, up-to-date firewall and anti-malware protection, and secure disposal of records containing personal information consistent with our own RIOS Certified Recycler data destruction standards.
5How We Share Your Information
We do not sell your personal information. We may share information only in the following limited circumstances:
Service Providers
We may share information with trusted third-party vendors who assist us in operating our website, processing payments, or delivering services (e.g., scheduling software, email platforms). These vendors are contractually required to protect your information and may not use it for their own purposes.
Legal Compliance
We may disclose information when required by law, court order, or governmental authority, including in response to a valid subpoena, regulatory inquiry, or to protect the rights, property, or safety of the Company, our clients, or the public.
Business Transfers
In the event of a merger, acquisition, or sale of all or substantially all of our assets, your information may be transferred as part of that transaction. We will notify you via email or prominent website notice before your information is transferred and becomes subject to a different privacy policy.
With Your Consent
We may share information for any other purpose with your explicit prior consent.
6Data Retention
We retain personal information for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:
| Data Type | Retention Period |
|---|---|
| Service records and chain-of-custody documentation | Minimum 3 years (RIOS Certified Recycler requirement) |
| Certificates of Data Destruction | Minimum 3 years; available to client on request |
| Invoice and payment records | 7 years (Massachusetts tax and accounting requirements) |
| Contact form submissions | 2 years or until request is fulfilled |
| Website analytics data | 26 months (standard analytics retention) |
| Email correspondence | 3 years from last interaction |
7Cookies and Website Tracking
Our website uses cookies and similar tracking technologies to improve your browsing experience and analyze site traffic. Types of cookies we use:
- Essential Cookies: Required for the website to function properly. Cannot be disabled.
- Analytics Cookies: Help us understand how visitors interact with our website (e.g., Google Analytics). Data is aggregated and anonymized.
- Preference Cookies: Remember your settings and preferences for a better experience on return visits.
You can control cookies through your browser settings. Disabling certain cookies may affect website functionality. We do not use cookies to track you across third-party websites or serve targeted advertising.
8Your Rights Under Massachusetts Law
As a Massachusetts resident or a client whose personal information we hold, you have the following rights:
Right to Access
You may request a copy of the personal information we hold about you.
Right to Correct
You may request correction of inaccurate or incomplete personal information.
Right to Delete
You may request deletion of your personal information, subject to our legal retention obligations.
Right to Opt Out of Communications
You may opt out of non-essential communications at any time by contacting us or using the unsubscribe link in any email.
Right to Notice of Breach
Under Massachusetts General Laws Chapter 93H, we are required to notify you promptly if a security breach results in unauthorized acquisition of your personal information.
To exercise any of these rights, contact us at info@techrecyclingsolutions.com or (508) 466-6100. We will respond within 30 days.
9Children's Privacy
Our website and services are directed to businesses and adult individuals. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have inadvertently collected personal information from a child under 13, we will promptly delete it. If you believe we have collected such information, please contact us immediately.
10Third-Party Links
Our website may contain links to third-party websites (e.g., the EPA, certification bodies, or industry resources). We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies before providing any personal information.
11Security Breach Notification
In the event of a security breach that results in unauthorized access to or acquisition of personal information, we will comply with Massachusetts General Laws Chapter 93H, which requires:
- Prompt notification to affected Massachusetts residents
- Notification to the Massachusetts Attorney General's Office and the Director of Consumer Affairs and Business Regulation
- Notification to major consumer reporting agencies if more than 1,000 residents are affected
12Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Policy at techrecyclingsolutions.com/privacy with a revised effective date. For material changes, we will provide additional notice (such as an email notification). Your continued use of our services after the effective date constitutes acceptance of the updated Policy.
13Contact Us
For questions, concerns, or requests related to this Privacy Policy or our data practices, please contact:
Privacy Officer — Surplus Technology Solutions dba Tech Recycling Solutions
Related Legal Documents
Disclaimer: This Privacy Policy is provided for informational purposes. It does not constitute legal advice. Clients with specific legal questions regarding data privacy are encouraged to consult qualified legal counsel licensed in Massachusetts.
Last updated: April 7, 2026 • Surplus Technology Solutions dba Tech Recycling Solutions • Waltham, Massachusetts