Protecting personal information is a core TRUSTe value. This Privacy Statement describes how TRUSTe collects, uses and discloses the personal information we receive or that you provide to us. It also describes the choices available to you regarding TRUSTe’s use of your personal information and the steps you can take to access this information and to request that we correct or delete it.
EU-U.S. Privacy Shield and U.S.-Swiss Safe Harbor Participation
TRUSTe participates in and has self-certified compliance with the EU-U.S. Privacy Shield Framework (“Privacy Shield”). TRUSTe is committed to applying the Privacy Shield Principles to all personal information received from countries in the European Economic Area (EEA) in reliance on the Privacy Shield. To learn more about the Privacy Shield, visit the U.S. Department of Commerce’s Privacy Shield website.
Under the Privacy Shield, TRUSTe is responsible for the processing of personal information it receives and subsequently transfers to a third party acting for or on its behalf. TRUSTe is liable for ensuring that the third parties we engage support our Privacy Shield commitments.
The U.S. Federal Trade Commission has regulatory enforcement authority over TRUSTe’s processing of personal information received or transferred pursuant to the Privacy Shield Framework.
TRUSTe also participates in and has self-certified compliance with the U.S.-Swiss Safe Harbor framework.
Dispute Resolution Program
We encourage you to use TRUSTe’s Dispute Resolution Program to report and resolve privacy complaints you may have concerning TRUSTe Certification or Dispute Resolution Program Participants or to report misuse of TRUSTe trademarks. If you choose to file a privacy-related complaint, we collect your name, email, and country. We also request you provide the details around your complaint. Any additional personal information you choose to provide on the complaint form is optional. We will use the information you provide to investigate your complaint and to send you an optional Customer Satisfaction Survey once your complaint is resolved.
We will not share your name or contact information with the TRUSTe Certification or Dispute Resolution Program Participant that is the subject of your privacy-related complaint unless you give us permission to do so. Please be aware, however, that if we cannot share this information, then we may not be able to resolve your complaint.
TRUSTe Contact Us Forms, Surveys, and Websites
We use information submitted through our Websites, in-person events and tradeshows, or collected through email or hard copy surveys to analyze the characteristics of our customers and improve our services. Occasionally, we will provide anonymized aggregated statistics about our customers in reports made available to our customers, to third parties, or to the general public. These reports will not identify individual TRUSTe customers.
If you request information about TRUSTe products and services, we will collect your name, email address, phone number, and additional company information. We use this information to contact you about your request, and to follow up with you about the products and services in which you have expressed an interest. We will also send information to you regarding upcoming TRUSTe events, webinars, and relevant privacy related news and alerts. You may unsubscribe from these communications at any time by clicking on the unsubscribe link provided in the email.
TRUSTe Customer Information
TRUSTe Customer Information is information we collect from you when you purchase and contract with us to provide services or technology solutions. We will ask you provide the following information:
- Email address;
- Phone number;
- Information regarding your role within your company;
- Company information, including company name, address, billing information, and company size,;
- Contact information for other relevant points of contact within your company as needed in order for TRUSTe to provide its services.
If you purchased one of TRUSTe’s technology solutions such as Assessment Manager, you may have the option to add additional users to your account. We will ask for the name and email address of the additional users you want to add. This information is only used by TRUSTe to provide the requested service unless that user signs up to receive other TRUSTe communications.
We will use your Customer Information to:
- Provide the services and access to the technology solutions you have purchased;
- Provide customer support. While providing you with customer support we may also gather additional information from you to investigate technical issues, and respond to your support questions;
- Communicate regularly with you about your use of the service, TRUSTe events and other industry or privacy-related news, and other TRUSTe services we believe may be of interest to you. You may opt-out of receiving emails regarding TRUSTe events and other TRUSTe services by clicking the unsubscribe link provided in the email. You will continue to receive notices regarding TRUSTe services and technology solutions you purchased, and privacy-related updates such as notification of new or changes to existing privacy regulations.
- Analyze the characteristics of our customers (e.g., types and size of companies) at an aggregated level and customer utilization of our products and services to in order to understand customer and market needs, to improve our existing products and services, to design new products and services, and for business development.
In the course of using TRUSTe’s technology solutions or services, you may provide business information related to your company. Business information may include copies of your company’s policies and process documents, responses to assessment questionnaires and evidence to support those responses. This is information is stored on TRUSTe’s systems, and is used to provide contracted services in accordance with the applicable terms and conditions of agreements between TRUSTe and your company.
If you are using the free version of TRUSTe’s Assessment Manager offered in partnership with IAPP, see the IAPP GDPR Readiness Assessment Powered by TRUSTe Assessment Manager Privacy Notice for information on how TRUSTe manages and uses the information collected through that service.
Information TRUSTe Receives from Third Party Sources
TRUSTe obtains business contact and company information from third party sources, such as business intelligence platforms The information obtained by these third party sources is from publicly available sources such as news articles. This information is used to support TRUSTe’s marketing and sales efforts. The TRUSTe sales team may contact you based on this information to gauge your company’s interest in TRUSTe’s services and technology solutions. You may opt-out of these communications at any time by clicking the unsubscribe link provided in the email or by sending a request to the TRUSTe Data Governance and Privacy Office using the Contact Us form available on this page.
If you sign up for TRUSTe blog update alerts, webinars, or other communications, download a whitepaper or other business resources, or you want to contact us generally, we will collect your contact information to fulfill your request. We may also contact you regarding TRUSTe events and webinars, and TRUSTe services we believe may be of interest to you. To unsubscribe from TRUSTe communications, follow the unsubscribe link that appears at the end of each email communication. You will be unsubscribed from all TRUSTe communications.
Consumer Opinion Surveys
From time to time we will also offer you the opportunity to receive information about privacy-related products or services offered by our third-party partners. We will not share your personal information with these third parties for their marketing purposes, unless we have your permission to do so.
Consumer Opinion Surveys
We, along with third party partners we engage for this purpose, will occasionally conduct online consumer surveys to learn about your views on important privacy issues. We do not collect personal information in these surveys. We use the survey data for research and to improve our services.
TRUSTe may also collect information about your interests through its TRUSTed Interests tool accessible through an icon placed in an ad. To learn more about how TRUSTe uses your interest data click here. To access and view interest information you have provided us click here. Please note – to view your interests you will need to access the link using the same device from which your interests were originally set.
Cookies and other data collection technologies
- Help you navigate our website or technical solutions
- Personalize your experience
- Analyze which pages our site visitors visit, and features being used on our technology solutions, and consumer privacy tool
- Provide feature such as social sharing widgets and videos
- Measure advertising and promotional effectiveness
- Assess which areas of our site you visit to remarket to you after you leave our site
- Provide content from our third party content partners
We work with a third party to track your activities on our web site to improve our marketing efforts and provide you advertising based on your visit. If you do not want to have your information collected and used for remarketing purposes you can opt-out through TRUSTe’s Preference Manager tool by clicking here. TRUSTe complies with the Digital Advertising Alliance Principle for Online Behavioral Advertising. If you opt-out of retargeted online ads, you will still continue to see and receive other online advertisements.
Videos and other features on our site use Flash cookies to collect and store your preferences such as sound volume. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored. Cookie management tools provided by your browser will not remove Flash cookies. To learn how to manage privacy and storage settings for Flash cookies click here.
Please note that some cookies may be placed by a third party service provider who performs some of these functions for us.
Information Automatically Collected By Our Site
We automatically gather server log file information such as your IP address, browser type, referring/exit pages, and operating system. We use this information to administer our website and our technical solutions, understand how visitors navigate through our Sites and services, and to enhance your experience while using our Sites and services.
We may disclosure your personal, customer, or business information to companies that provide services to help us with our business activities such as website analytics or offering customer service. These third parties are authorized to use your personal information, customer or business information only as necessary to provide these services to us.
We may also disclose your personally identifying information
- As required by law such as to comply with a subpoena, or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information, customer or business information to third parties as part of legal process. TRUSTe also may be required to disclose personal information in response to lawful requests by public authorities, including requests from national security or law enforcement authorities.
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a written government request
- If TRUSTe becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure that the acquiring organization agrees to protect personal information subject in accordance with the commitments we have made in this Privacy Statement, including our Privacy Shield commitment and that they will provide notice before personal information, customer or business information becomes subject to a different privacy statement
- To any other third party with your prior consent to do so
We will share your personal information, customer or business information with third parties only in the ways that are described in this Privacy Statement. We do not otherwise sell your personal information to third parties.
Accessing and Updating your Personal Information
To review and update your personally identifying information to ensure it is accurate, contact us.
TRUSTe will make commercially reasonable efforts to provide you reasonable access to any of your personal information we maintain within 30 days of your access request. We provide this access so you can review it, make corrections or request deletion of your data. If we cannot honor your request within the 30-day period, we will tell you when we will provide access. In the unlikely event that we cannot provide you access to this information, we will explain why we cannot do so.
Security and Data Integrity
Safeguarding the information you give us or we receive about you is a priority for TRUSTe. We take appropriate security measures to protect against loss, misuse and unauthorized access, alteration, disclosure, or destruction of your information. TRUSTe has taken steps to ensure the ongoing confidentiality, integrity, availability and resilience of systems and services processing personal information and to restore the availability and access to information in a timely manner in the event of a physical or technical incident.
We will retain personal information, customer and business information for as long as it is needed to:
- Provide products and services that you or your organization have requested;
- Communicate with you about a request you have made to us;
- Manage your choices and rights you have exercised pursuant to this Privacy Statement;
- Enable you to maintain an account with us, provided that you or the organization through which your account was created have not otherwise requested that we delete your information;
- Comply with our legal and regulatory obligations, demonstrate compliance, and to enforce TRUSTe’s rights and agreements.
Links to Other Web Sites
This Privacy Statement applies to TRUSTe services only. Our Site and technology solutions includes links to other Websites. If you submit personal or other information to any of those sites, your information is subject to their privacy statements. We encourage you to carefully read the privacy statement of any Website you visit.
Changes to this Privacy Statement
Please note that this Privacy Statement may change from time to time. If we change this privacy statement in ways that affect how we use your personal information, we will advise you of choices you may have as a result of those changes. We will also post a notice on our home page that this Privacy Statement has changed.
Questions regarding this Privacy Statement
Questions regarding TRUSTe’s privacy and information management practices can be submitted to the TRUSTe Data Governance and Privacy Office using the Contact Us form available on this page.
If you are a resident of the EEA and have an unresolved privacy or personal information collection, use or disclosure concern that we have not addressed satisfactorily, please contact the EU Data Protection Authorities. In connection with its self-certification under the Privacy Shield, TRUSTe commits to cooperate with the panel established by the EU Data Protection Authorities and comply with the advice given by the panel with regard to personal information transferred from the EU. This is provided at no cost to you.
For more information on how to contact the EU Data Protection Authorities, click here.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
If you are a resident of Switzerland and have an unresolved privacy or personal information collection, use or disclosure concern that we have not addressed satisfactorily, please contact the Swiss FDPIC. TRUSTe has agreed to cooperate with the Swiss FDPIC for unresolved disputes regarding personal information we receive from Switzerland.
The following terms used in this Privacy Statement have defined meanings.
- Personal information. Any data about an identified or identifiable individual, including data that identifies an individual or that could be used to identify, locate, track, or contact an individual. Personal information includes both directly identifiable information such as a name, identification number or unique job title, and indirectly identifiable information such as date of birth, unique mobile or wearable device identifier, telephone number as well as key-coded data.
- Third party. Any legal entity, association or person that is not owned by TRUSTe, or in which TRUSTe does not have a controlling interest.
- TRUSTe. TRUSTe Inc. and its subsidiaries and successors worldwide, including without limitation, its subsidiary in the Philippines.
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