Effective: 18 November 2020

Learning about our company and our solutions: If you request or indicate an interest in information about our solutions or partnership opportunities, we process your name, email address, phone number, job title, information about the company where you work, including its website address, and any comments you provide. We append business information related to the company where you work from third party sources, such as business intelligence providers, information from publicly available sources, such as LinkedIn, as well as information about the number and frequency of your interactions with us online and offline, such as at events, webinars, via email and our website. We maintain and update this information as we continue to engage with you and use it as described under the Legitimate Interests processing purposes described below.

Using the TrustArc Privacy Platform: If you are a licensed or other authorized user of our privacy technology platform, we process your name, email address, username, password, IP address, job title, phone number, information about the company where you work, actions you have taken in the applications on the platform, such as record creation, changes, input, responses, analysis, and approvals, and tickets filed on your behalf related to our platform.

• TrustArc-IAPP Assessment Manager: If you are using the free version of our Assessment Manager offered in partnership with the IAPP, we process your name, email address, company name, and password. Please refer to the Privacy Notice for that service for more information.

Participation in our Assurance Programs and Solutions: If you participate in our certification or verification programs, or our GDPR validation, we process your name, email address, country, phone number, job title and company name.

Using our Consulting Services: If you engage us to provide consulting services, we process your name, email address, postal address, job title, signature, and company information.

Negotiating and entering into a contract with us and relationship management during the contract term: If you enter into an agreement with us related to the licensing or purchase of our solutions, we process your name, email address, postal address, company name, billing information (e.g., purchase order number, bank wire information, credit card number), company size, company financial information, and signature.

Receiving marketing, sales-related and business development communications from us: If our marketing team or a member of our sales or business development teams sends communications to you, we process your name, phone number, email address, postal address, job title, job function, company name, company size, company financial information, IP address, device type, email view information including IP address and associated city, and information about which of our solutions you use or which may be of interest to you.

Market research and surveys: If you participate in our market research and surveys, we process your email address, job title, phone number, survey responses, company name, job function, state, country, and any comments you provide.

Participation on a recorded telephone call or video conference with TrustArc: If you have consented to a recorded telephone call or video conference with TrustArc, we may process your name, email address, job title and voice for analytical purposes to improve our training and customer relationship management, as described in the Consent processing purposes section below. For any such telephone calls or video conferences, notice of the recording will be provided in advance and during the meeting. You may decline recording at any time before or during the meeting, and you may request deletion of the recording at any time. All such recorded meetings will be automatically deleted within 180 days.

Webinars & Podcast:If you are invited to be a guest in a TrustArc hosted or sponsored webinar or in our Serious Privacy Podcast, your business contact information will be processed as part of the production. This includes your name, email address, phone number, company name and job title. These programs are recorded and broadcast publicly, as is the nature of such programs, which includes your voice and the information you share during such programs.

Our website: We process personal information about you that we collect either directly, through forms or data entry fields on our website, or through passive collection by cookies and other data collection technologies. The types of personal data we process in each of these contexts is further explained in the following four categories:

• Contact us and registration forms: we process your name, email address, company where you work, phone number, job function, job title, country, and any comments you provide.
• Consumer opinion surveys: we process your survey responses
• Cookies and other data collection technologies: we use browser session cookies, which are temporary cookies that are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, unless you delete them before that time. We group browser cookies on our site into three categories, which you can manage through our “Cookie Preferences” manager:
  • Required cookies: These cookies are necessary to enable the basic features of this site to function, such as allowing images to load or allowing you to select your cookie preferences.
  • Functional cookies: These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your log-in details or providing us information about how our site is used.
  • Advertising cookies: These cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.

  Videos and other features on our site use Flash cookies to collect and store your preferences, such as volume. Flash cookies are different from browser cookies because of the amount of, type of, and way that 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.
  Some cookies may be placed by third party service providers who perform some of these functions for us.

• Server log files: We automatically gather server log file information when you visit our websites. This includes IP address, browser type, referring and exit web pages, and your operating system.

Cookie Preference Manager: If you use our preference manager on a mobile device, we process your device’s Advertising Identifier. When you access our preference manager, session cookies will be set by the ad networks listed in our preference manager to honor your preferences if you choose not to receive interest-based advertising. If you clear your browser cookies, this will remove all cookies including the opt-out cookies set by the companies. You will need to re-access the opt-out tool to reset your preferences. Our cookie only knows your last set of preferences and does not reflect the current state of cookies on your browser.

Individual Rights Manager: When you submit a request related to our processing of personal information about you, we process your name, email address, residence, type of request, the individual type you select on the form, any comments you provide, and any additional information needed to verify your identity. When you submit a request to another company that has implemented our Individual Rights Manager, we process the information you provide in the form implemented by that company, and we support the management of your request by the company as well as retrieval of information responsive to your request.

Direct Marketing Consent Manager: If a company has implemented our Direct Marketing Consent Manager, we process a pseudonymous identifier related to you to help that company manage your consent preferences. TrustArc uses this approach to allow the company to manage your personal information rather than TrustArc.

Ads Interests Manager: If you click through an icon associated with our Ads Interests Manager in an online advertisement, we process information about your interests.

TrustArc Ads Compliance Manager: We process cookies to deliver our interest-based advertising notice and choice program’s opt-out tools to assist with your opt-out choices and to help us measure usage. Our opt-out tool signals companies to not use your browsing behavior to provide interest-based advertising by setting their opt-out cookie in your browser. When you access our preference manager, session cookies will be set by the ad networks listed in our preference manager to honor your preferences if you choose not to receive interest-based advertising. If you clear your browser cookies, this will remove all cookies including the opt-out cookies set by the companies. You will need to re-access the opt-out tool to reset your preferences. Our cookie only knows your last set of preferences and does not reflect the current state of cookies on your browser.

TRUSTe 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 file a privacy-related complaint, we process your name, email, and country location. We will also request that you provide the details that gave rise to your complaint. Any additional personal information you choose to provide in the complaint form is optional.

Serious Privacy Podcast: if you listen to our Serious Privacy podcast, your IP-address and some other technical information may be shared with your podcast application and/or our hosting provider Buzzsprout. TrustArc has no access to the data of our listeners, except at aggregate level.

Applying to work at TrustArc: If you apply to work at TrustArc, we process personal information about you and your professional experience, education and training such as your application, your name (and any former names), postal address, email address, phone number, universities attended, academic degrees obtained, grades, professional certifications and licenses, employment history, and curriculum vitae or resume.

Offer of employment or contractor position: Prior to making an offer of employment or a contractor position, we process personal information to conduct professional reference checks in accordance with applicable laws. If we extend an offer of employment or a contractor position at TrustArc to you, we will process personal information about the position to which you have been appointed, your job title at TrustArc, the compensation or project-based contractor rate we offer to you, whether you accept the offer, your signature, and your starting compensation or project-based contractor rate, and your start date at TrustArc.

Employment-Related Background checks: Prior to commencement of your employment with us, we engage service providers to conduct background checks that involve the necessary personal information processing as permitted by the laws in the location in which you reside and/or work. More details are provided to you in the context of our request to you to complete these checks.

As an employee or contractor of TrustArc: we may process personal information about your benefits, nationality, residency status, email address, office or other workplace location, work phone number, mobile phone number, photographs, passport, visas, marital status, beneficiaries, emergency contact details, financial account information, social security number or other government-issued identification number, holiday and paid time off days, salary, incentive compensation, TrustArc stock options granted, TrustArc stock ownership, assigned projects, performance against your assigned goals, training completed, any performance improvement plans, any disciplinary actions taken, system accounts, technology and physical assets provided to you, your role and actions taken in connection with TrustArc projects and processes.

If your employment with TrustArc ends, we process personal information necessary to offboard you from TrustArc, including deactivation of your access to our systems, fulfilling our financial, benefits, and related obligations with respect to the end of your employment with TrustArc.

In certain countries, supplemental privacy notices will be provided to TrustArc employees and contractors, and where applicable, consent will be obtained, to ensure compliance with local requirements.