Version 1.0
LAST UPDATED ON: 06.06.2023
1.General Information.
1.1 Scope. Tromml, a North Carolina LLC (“Company”, “We”, “Us” and “Our”), respect your privacy and are committed to protecting it through Our compliance with this Privacy Policy (this “Policy”). This Policy describes how We collect, process, and disclose information related to you as a natural person (“Personal Data”), and what rights you have with respect to the processing of your Personal Data.
This Policy applies when you:
If you decline to provide your Personal Data or ask Us to delete it, you may not be able to access or use the Services.
1.2 Update of This Policy. We may change or substitute this Policy at any time in Our sole discretion. You should check back regularly for the most up-to-date version of this Policy and whenever you access one of the Services.
2. Data Categories. The categories of data We collect and/or process depend on your interactions with Us and may include one or more of the following data categories:
2.1 Contact and Business Data. Contact data includes last name, first name, email address, physical address, phone number, country of origin, usernames, passwords and other similar information. Business data refers to information on position, company name and other similar information.
2.2 Communication and Transaction Data. Communication data refers to the data resulting from your interaction with Us, including but not limited to, emails, chat messages, webinars visited, files downloaded and product interest information. Transaction data refers to registration information related to your attendance at one of Our events, including travel information, scheduling information, food preferences or allergies, and accessibility requests.
2.3 Device and Browser Data. Device and browser data refers to online and technical information from your computer or mobile device, such as device type, location, information about the browser type and version, the operating system and version, the ISP or mobile carrier, the IP Address (or proxy server) and geographic areas derived from your IP address, time and date of access, duration of access, referring URL (if any) and identifiers that help Us recognize your device and validate that you are a licensed user.
3. Origin of the Data. In most cases, you provide Personal Data directly to Us by accessing the Website or by registering and/or using the Services. We may also obtain Personal Data from your employer in the context of providing the Services or from third party suppliers, social networks, or partners. To enable collection of data, We might use cookies, web beacons or similar technologies.
4. Purposes for Processing. We use Personal Data collected as described in this Policy, as specified in any terms that incorporates this Policy, or as disclosed to you in connection with the Services.
4.1 Providing the Requested Service. We collect and process your Personal Data to fulfill Our contractual obligations to you, including to:
4.2 Comments and Questions. If you contact Us via the Website, via email or in any other way, We process your Personal Data to understand and respond to your request and to provide customer service. In such circumstances, your request might be internally forwarded to the responsible department.
5. Lawfulness of Processing. When We collect and use your Personal Data, We will only do so where at least one of the following applies:
5.1 We need to process your Personal Data to perform Our responsibilities under Our contract with you and to provide you with tools and services; [see Art.6 Para 1(b) GDPR].
5.2 We have a legitimate interest to process your personal information; [see Art.6 Para 1(f)GDPR]
5.3 You have given consent to process Personal Data; or [see Art.6 Para. 1(a) GDPR]
5.4 It is necessary for Us to process your Personal Data to comply with a legal obligation. [seeArt.6 Para. 1(c) GDPR]]
6. Cookies and Other Tracking Technologies. We use session-based and persistent “cookies” and similar technologies such as web beacons to increase user-friendliness and compile information about the usage of the Website. Cookies are created either by Us (first-party cookies) or by third-party providers determined by Us (third-party cookies). The following describes the types of further cookies.
We utilize:
6.1 Necessary Cookies. Some cookies are required for the purposes of delivering basic functionality of the Website, including for security and authentication purposes. These cookies are strictly necessary for the operation of the Website.
6.2 Functional Cookies. Functional cookies enhance the functions and services on the Website. Although such cookies are not entirely necessary; without cookies some of the Website functionality may become unavailable (such as interactive content, web chat, video, and personalized content).
6.3 Performance Cookies. Performance cookies collect the Website usage data and are aggregated to provide useful information that will be used to help Us improve the performance and contents of the Website.
Marketing Cookies. Cookies are used to ensure that advertising and content is relevant for you and to track activity across websites in order to improve the quality of advertising targeted to you (“Marketing Cookies”). Marketing Cookies also include cookies provided by social media and other third-party websites, which may also be used for advertising.
7. Recipients.
7.1 Your Personal Data may be transferred to affiliates and partners of Company as well as to a limited number of service providers that perform processing operations such as database monitoring, hosting services, ticketing or provisioning of software tools. These service providers process Personal Data on Our instructions only and have implemented reasonable measures to safeguard any processed data.
7.2 When We ask third parties to host or present at certain events like webinars or training, We may forward your Personal Data to the respective third party who may use this data to provide access to the event or may contact you for related marketing purposes.
7.3 [If Personal Data is transferred to subsidiaries, partners service providers or third parties located outside the European Economic Area (EEA) which are not subject to an adequacy decision by the European Commission We will ensure that such recipient offers an adequate level of data protection, for instance by entering into EU Standard Contractual Clauses (SCCs) and implementing additional safeguards in accordance with legal requirements, or We will ask you for your prior individual consent to such international data transfers.]
7.4 We may disclose your Personal Data to comply with legal requirements, such as in response to a court order or a subpoena. In such an event, We will use all reasonable and lawfully available measures to object to overbroad, unclear or otherwise inappropriate requests for information, and will cooperate with those seeking a protective order unless We are legally prohibited from doing so. We may also share Personal Data with Our auditors, attorneys or other advisors under professional obligations of confidentiality in connection with corporate functions.
8. Duration of Data Storage.
8.1 Your Personal Data will be deleted upon your request or as soon as it is no longer required to achieve the purpose for which Personal Data has been collected, namely, to provide the requested Services. If legal regulations (e.g., by fiscal, commercial, or contractual law) apply that require longer storage of your Personal Data, or if We need your Personal Data to assert legal claims or defend against legal claims, We will store your Personal Data until the expiration of the corresponding storage period or until the settlement of the claims.
8.1 [Any user account and its related data in applications where We act as a controller who determines the purposes and means of processing of Personal Data (“Controller”) will be deleted upon your request.]
9. GDPR Rights.
9.1Upon request, We will inform you whether and which data We have stored about you. Insofar as the legal requirements are met, you have the right to have this data corrected, blocked or deleted. You also have the right to receive Personal Data which you have provided to us, in a structured, commonly used, and machine-readable format and have the right to transmit those data to another Controller under conditions and in accordance with the Regulation.
9.2 Insofar as We process your data on the basis of the balancing of interests, you have a right of objection if the legal requirements are met.
9.3 Where We are relying on consent to process your Personal Data you may withdraw your consent at any time for the future. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
9.4 You may exercise your rights by contacting Us in writing, with a proof of your identity, at [EMAIL ADDRESS].
9.5 If you are resident of the EU, you also have the right to direct questions or complaints to the lead supervisory authority.]
10. California Privacy Rights. This section provides additional details about Personal Data We collect about California residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”). For purposes of the CCPA, the defined term “Personal Data” is the same as the term “Personal Information” as such term is defined in the CCPA.
10.1 For more details about Personal Data We have collected over the last 12 months, including the categories of sources, please see Section 2. We collect this information for the business and commercial purposes as described in Section 4. We share this information with the categories of third parties described in Section 7. We do not sell, as such term is defined in the CCPA, Personal Data We collect and will not sell or use Personal Data without providing a right to opt out.
10.2 Subject to certain limitations, the CCPA provides you the right to request to know more details about the categories or specific pieces of Personal Data We collect (including how We use and disclose this information), to delete your Personal Data, to opt out of any sales that may be occurring, and to not be discriminated against for exercising these rights.
10.3 You may make a request pursuant to your rights under the CCPA by contacting Us at www.tromml.com. We will verify your request using the information associated with your the information associated with your account (if any), including email address. Government identification may be required. You can also designate an authorized agent to exercise these rights on your behalf.