2 PRIVACY FRAMEWORKS
As set forth by the U.S Department of Commerce, the European Commission and the Swiss Commission, the EU-US and Swiss-US Privacy Shield frameworks have been set forth to ensure citizens of the European Union and Switzerland are provided data protection policies that comply with those in their respective countries when data is transferred to the U.S. TRG is committed to the protection of personal information for all our clients and visitors and implemented policies that adhere to these principles.
2.1 EU-US Privacy Shield
TRG has certified that it adheres to the EU-U.S. Privacy Shield Framework; Privacy Shield Principle of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.
To learn more about the Privacy Shield program, and to view TRG’s certification, please visit www.privacyshield.gov.
2.2 Swiss-US Privacy Shield
To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.
3 INFORMATION COLLECTED
Through your use of this various TRG applications and public websites, TRG may possess certain information regarding visitors to publicly accessible websites and the employees and contractors of the businesses that have licensed the use of TRG applications (“Licensee”). Such information is referred to as the “Information”.
3.1 Personal Information
We collect and store information you enter when asking for information about TRG Services, registering for and using TRG Services, or provide to us in any other way.
In addition, Licensee’s may provide (at its discretion) certain personal information including, without limitation, their employee names, work titles, work addresses, business telephone numbers and other personal information (i.e. IP address, etc.).
3.2 Usage Information
TRG may record your usage details such as time, frequency, duration and patterns of use, features used, Internet Protocol address, browser type, browser language, referring URL, files accessed, errors generated, time zone, operating system, and other visitor details collected in our log files to analyze the trends, track user behavior and administer and improve TRG services.
3.3 Additional Information
TRG may learn certain information regarding vendors and third parties with whom Licensee conducts business and certain other confidential and proprietary information regarding Licensee.
3.4 User-Generated Content
We may provide the ability for users to post information to public and semi-public spaces on TRG websites (for example public and private blogs or customer support sites). Some of this information may be publicly available to users outside of TRG. When using any public or semi-public TRG website, we encourage users to be cautious in disclosure of Personal Information, as TRG is not responsible for the Personal Information users elect to disclose.
4 HOW INFORMATION IS USED
Information provided through TRG owned public websites is used by TRG for purposes in which it was intended when provided. This includes marketing as well as support and system administration services.
For Information provided to TRG through licensed services, TRG shall use the Information provided to it only in connection with the provision of services by TRG on behalf of Licensee and as otherwise permitted pursuant to such agreements between TRG and Licensee.
We will never share your information with a third-party except in cases where the third-party has been contracted by TRG to assist in the provisioning of the services provided.
TRG is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequent transfers to a third party acting on its behalf. TRG complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data transferred or received pursuant to the Privacy Shield Framework, TRG is subject to the regulatory enforcement power of the U.S. Federal Trade Commission. In certain situations, TRG may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Unless prevented by court order, TRG will attempt to provide advance notice of such a lawful request for disclosure prior to complying with the order.
In the event that TRG posts user/client testimonials on the TRG Websites, such testimonials may include names or other personal information. We acquire permission from our users and clients before posting these on the TRG Websites. TRG is not responsible for Personal Information users elect to include in their testimonials.
TRG respects the choices of those visiting our sites and using our services. Users whose information is collected through our public sites have a choice regarding how that information is used. TRG provides an unsubscribe / opt-out option on all marketing communications. Users whose information is held by TRG as part of licensed service should contact the licensee to opt out.
TRG is dedicated to protecting the privacy of all users of TRG Services and providing our Licensees with the highest level of service and security. In furtherance thereof, TRG has implemented practices and procedures designed to safeguard the privacy and security of the Information. To demonstrate our commitment to Information Security, TRG submitted our Information Security Management System to an independent third-party review and has been certified compliant to the ISO/IEC27001:2013 standard through an accredited certification body.
6 HOW YOU CAN HELP
You can take steps to protect the privacy of the Information. Do not share your account information, passwords, user ID’s, PINs, code words or other confidential information with others. When conducting business over the Internet, always use a secure browser, exit online applications as soon as you finish using them, and make sure you have virus protection and a firewall and update them regularly. Protect and properly dispose of your account records.
7 ACCESSING, UPDATING and REMOVING PERSONAL INFORMATION
Users that have submitted their information through one of TRG’s public sites can request access to see the information being held by TRG as well as request to have the data updated or removed by sending an email to email@example.com. Please note that a response and / or changes can take anywhere from 48hrs to 30 days to complete.
Requests regarding personal information stored by TRG as part of a licensed product should be directed toward the Licensee as the party that has submitted the information. TRG will provide assistance in contacting and working with the User and Licensee upon request.
8 DISPUTE RESOLUTION
TRG has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss-U.S. Privacy Shield Principles to an independent dispute resolution mechanism through the European Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship. TRG commits to comply with the decision / recommendation of the DPAs.
If you are a customer located in an EU Member State there are certain conditions, more fully described on the Privacy Shield website, under which you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
9 OTHER AGREEMENTS
TRG and Licensee may have entered into other agreements regarding the privacy of the Information. In this regard, all agreements between TRG and Licensee must be reviewed in connection with TRG’s privacy actions.
TRG welcomes the opportunity to answer any questions you may have about this statement or the safeguarding and confidentiality of information. For more information, please contact us at firstname.lastname@example.org.
11 RIGHT TO CHANGE PRIVACY STATEMENT
TRG reserves the right to change this privacy statement at any time. Changes will be effective immediately upon posting.
Last updated: July 17, 2017