Last Updated: October 9, 2018
"Personal Information," as used in this Policy, is any information relating to an identified or identifiable individual.
We may collect Personal Information about you from various sources described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Service if that information is necessary to provide you with it or if we are legally required to collect it.
We collect Personal Information that our users provide to us in a variety of ways on our Services. These include the following:
Email Newsletters. We may offer email newsletters from time to time on our Services. If you sign up to receive a newsletter from us, we may ask you to provide Personal Information, such as your email address.
User Accounts and Profiles. Our Services may give you the ability to register for a TrustedSite account or to create and update a user profile on the applicable Service. If we offer user account or profile functionality on the Services, we may collect the Personal Information that you provide to us in the course of registering for an account or creating or updating a user profile. This information may include your name, postal address, telephone number, email address, and related demographic information about you. We will indicate which Personal Information is required for you to register for the account or to create the profile.
Interactive Features. Our Services may contain interactive functionality that allows you to engage with other users on the Services, post comments to forums, to upload photographs and other content (the "User Materials"), participate in surveys, and otherwise to interact with the Services and with other users. If you use any interactive functionality on our Services that request or permit you to provide us with Personal Information (including, for example, any services that allow you to post User Materials on any of our Services), we may collect the Personal Information that you provide to us in the course of using these interactive features.
Correspondence. If you contact us by email, using a contact form on the Services, or by mail, fax, or other means, we may collect the Personal Information contained within, and associated with, your correspondence. For example, if you send us a customer service-related request, we will process the content of your message, the date and time of your message, our response and any other Personal Information you provide in that context.
Job Applications. If you contact us to apply for a job with TrustedSite, we will process your job application, including your resume and other Personal Information you submit to us in that context.
When you visit our Services, some Personal Information may be collected automatically. For example, when you access our Services, we automatically collect your browser's Internet Protocol (IP) address, your location, and your browser type. We may also collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as "Web beacons").
We may also implement third-party content or advertising on the Services, which allow the third-party content provider to read and write cookies to your browser in connection with your viewing of the third party content on the Services. Additionally, we may implement third party buttons (such as Facebook "like" or "share" buttons) that may allow third parties to collect information about you through such third parties' browser cookies. Also, please be aware that third parties ("Third-Party Sites") that may be linked to from the Services, may set cookies on your hard drive or use other means of passively collecting information about your use of their services, Third-Party Sites or content. We do not have access to, or control over, these third-party means of passive data collection.
We may receive information about you, including Personal Information, from third parties such as website platforms or partners, and may combine this information with other Personal Information we maintain about you. If we do so, this Policy governs any combined information.
We may collect information about you, such as name, address, phone number, and email address from publicly accessible sources, including public databases and other third parties.
We may use your Personal Information for the following purposes:
If you are located in the European Economic Area or Switzerland, we only process your Personal Information based on a valid legal ground, including: consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you, for example to deliver the Services or respond to your inquiries), our or a third party's legitimate interests (for example, to personalize our Services and provide you with tailored content, conduct business analytics, and otherwise improve the safety, security, and performance of our Services) or to comply with our legal obligations. We only rely on our or a third party's legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
Except as described in this Policy or as otherwise disclosed to you at the time of collection, we will not disclose your Personal Information that we collect on the Services to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
We may disclose Personal Information to third-party service providers (e.g., payment processing and data storage and processing facilities) that assist us in our work such as Amazon Web Services, Zendesk, and Customer.io. We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such Personal Information.
Some features on our Services may allow you to upload, post, or otherwise transmit User Materials to public areas of the Services, such as content that you post in a public profile on the Services. Any Personal Information that you voluntarily choose to include within any User Materials or in a publicly accessible area of the Services may be shared with individuals with access to such public areas.
Please note that while we may allow you to select privacy options that limit access to some types of Personal Information in User Materials, no security measures are impenetrable or perfect. Additionally, even after information posted on the Website is removed, caching and archiving services may have saved that information, and other users or third parties may have copied or stored the information available on the Services. We cannot warrant or guarantee that any Personal Information that you provide on and in connection with the Services will not be accessed, viewed, or used by unauthorized persons.
We may make these User Materials available for display upon Company properties that are not governed by this Policy, as well as to services operated by third parties that display content from the Websites (collectively, "Syndicated Services"). Personal Information that you include within any User Materials may be made available to other users of the Syndicated Services.
We may make certain automatically-collected, aggregated, or otherwise de-identified information available to third parties for various purposes, including: (a) compliance with various reporting obligations; (b) for business or marketing purposes; or (c) to assist such parties in understanding our users' interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, or functionality available through the Services.
Information about our users, including Personal Information, may be disclosed and otherwise transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of TrustedSite assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.
We also disclose Personal Information if we believe that doing so is legally required, or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others, or otherwise to help protect the safety or security of our Services and other users of the Services. We may disclose your Personal Information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. copyright law), or other applicable laws depending on your country, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving commercial email from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by email at email@example.com or by writing to us at the address given at the end of this policy. Additionally, if we offer user account functionality on the Services, we may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us.
Please be aware that if you opt-out of receiving commercial email from us, it may take up to ten business days for us to process your opt-out request, and you may receive commercial email from us during that period. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services.
If we offer the ability to create user accounts or profiles on our Services, you may have the ability to access and update many categories of Personal Information that you provide to us by logging in to your account and accessing your account settings. If you wish to access or amend any other Personal Information we hold about you, you may contact us at firstname.lastname@example.org.
If you request that we delete your account on any of our Services (via a user settings page, by email, or otherwise), we will do so within a reasonable period of time, but we may need to retain some of your Personal Information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so, subject to this Policy.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Websites. Please note that TrustedSite does not process or respond to web browsers' "do not track" signals or other similar transmissions that indicate a request to disable online tracking of users who use or visit our Services.
In some countries and in particular if you are located in the European Economic Area or Switzerland, you may have the right to:
Those rights may be limited in some circumstances by local law requirements. You may exercise your rights by contacting us as specified below. We will respond to any complaints as soon as possible and within thirty (30) days, but we may first need to request additional information from you to confirm your identity.
Our servers and data centers are located in the United States. If you choose to use the Services from outside the U.S., then you should know that you are transferring your Personal Information outside of your region and into the U.S. for storage and processing. By providing your Personal Information to us through your use of the Service, you agree to that transfer, storage, and processing in the U.S. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. You should know that each region can have its own privacy and data security laws, some of which may be less stringent as compared to those of your own region.
If you are located in the European Economic Area or Switzerland, we may transfer your Personal Information to countries which provide an adequate level of protection under EU and Swiss law.
TrustedSite 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. TrustedSite has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy 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 https://www.privacyshield.gov/.
TrustedSite is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and under certain conditions, individuals may invoke binding arbitration as well as learn more about TrustedSite's liability in cases of onward transfers to third parties at: https://www.privacyshield.gov/Individuals-in-Europe.
You may contact us as specified below to obtain a copy of the safeguards we use to transfer Personal Information outside of the European Economic Area and Switzerland.
We use reasonable security measures that are designed to protect Personal Information from accidental loss, disclosure, misuse, and destruction. We also maintain procedural safeguards to further restrict access to your Personal Information to employees who need it to perform their tasks (or people working on our behalf and under confidentiality agreements). Please be aware, however, that no data security measures can be guaranteed to be completely effective. Consequently, we cannot ensure or warrant the security of any information that you provide to us. You transmit information to us at your own risk.
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
The Services may contain links to other websites, products, or services that we do not own or operate. For example, the Services may contain links to third-party merchants from which users may purchase sound recordings that are streamed through the Services. The Services also may contain links to Third-Party Sites such as social networking services. If you choose to visit or use any Third-Party Sites or products or services available on or through such Third-Party Sites, please be aware that this Policy will not apply to your activities or any information you disclose while using those Third-Party Sites or any products or services available on or through such Third-Party Sites. We are not responsible for the privacy practices of these Third-Party Sites or any products or services on or through them. Additionally, please be aware that the Services may contain links to websites and services that we operate but that are governed by different privacy policies. We encourage you to carefully review the privacy policies applicable to any website or service you visit other than the Services before providing any Personal Information on them.
Under California's "Shine the Light" law, California residents who provide Personal Information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information shared, the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year, and descriptions of the likely types of marketing the third parties would send.
To obtain this information from us, please send an email message to email@example.com or mail us at the address below with "Request for California Privacy Information" on the subject line and in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
Children's safety is important to us, and we encourage parents and guardians to take an active interest in the online activities of their children. Our Services are not directed to children under the age of 13, and we do not knowingly collect Personal Information from children under the age of 13 without obtaining parental consent. If we learn that we have collected Personal Information from a child under the age of 13 on our Services, we will delete that information as quickly as possible. If you believe that we may have collected any such Personal Information on our Services, please notify us at firstname.lastname@example.org.
We may occasionally update this Policy. When we do, we will also revise the "last updated" date at the beginning of the Policy. Your continued use of our Services after such changes will be subject to the then-current policy. If we change this Policy in a manner that is materially less restrictive of our use or disclosure of your Personal Information, we will use reasonable efforts to notify you of the change and to obtain your consent prior to applying the change to any Personal Information that we collected from you prior to the date the change becomes effective. We encourage you to periodically review this Policy to stay informed about how we collect, use, and disclose Personal Information.
TrustedSite, LLC is the entity responsible for the processing of your Personal Information, except where we process your Personal Information on behalf of our customers. If you have any questions or comments about this Policy, your Personal Information, our use and disclosure practices, your consent choices or if you would like to exercise your rights, please contact us using the following contact information:TrustedSite, LLC