Effective Date: Mar 31, 2023
Last Updated on: Mar 31, 2023
This privacy notice explains how Trademo Technologies Inc and its affiliates, (“we”, “us”, “our”) Process personal information collected from natural persons as specified below in the section HOW DO WE COLLECT, USE, AND SHARE YOUR PERSONAL INFORMATION? as a controller (“you”). Capitalized terms used and not defined herein shall have the meaning set forth in the Agreement.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
1. HOW DO WE COLLECT, USE AND SHARE YOUR PERSONAL INFORMATION?
2. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
3. LEGAL BASIS FOR PROCESSING (EEA REGION)
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. WHAT SPECIFIC RIGHTS DO CALIFORNIA RESIDENTS HAVE?
11. NOTICE TO USERS AND OTHER EXCLUSIONS
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
| When You are a(n) | What personal information we collect | How we use your personal information | Whom we share your personal information with |
|---|---|---|---|
| Individual who registers for our Services. | Your contact information, such as your full name, email address, billing address, sign-up information, and any other information you provide us. |
| Third-party partners who assist us in onboarding you and creating your account, and providing the services to you. |
| Individual who submits feedback. | Information you have provided as part of it. | To improve our Services | Third parties who assist us in providing these services. |
| Individuals who submit web forms on our Website(s) or use interactive features of the Websites, including: participation in, surveys, contests, promotions, sweepstakes | Information you have provided as part of it. | To perform the function for which such surveys, contests, and promotions took place. | Third parties who assist us in providing these services. |
| Individual who requests Customer service or who reach out to us for other inquiry | Your name, usage information or any other personal information that you provide us in the course of such interaction. | To respond to Your comments and questions and provide customer service. | Third-party partners who assist Us in providing these services. |
| Individual who requests a demo. | Your contact information, such as your name, email address and phone number. |
| |
| Individual who applies for an Employment opportunity with us. | Your contact information, such as full name, email address, mobile number, phone number; details of your education and previous employment and any other information you volunteer, including during any interview or your interactions with us and contained in the resume that You submit to Us. | To evaluate you for any position that you have applied for or that we may consider you at the time that you submitted your resume or on a later date. | Third party partners who assist in the evaluation process like those that do employee background checks on our behalf. |
| When You are a(n) | What personal information we collect | How we use your personal information | Whom we share your personal information with |
|---|---|---|---|
| Website visitor |
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| Third-party partners who provide us with any analytics, marketing, hosting services, and other services in connection with such Processing. |
| Individual who registers to our services using social media account or any other third-party sign on services | Your social media account information that you have made public on such social media accounts. |
| |
| Individual whose information is available on public platforms. | Your full name, email address, phone number, business information, designation, resume, interests, statistical information, and any other personal information that you may share on such a public platform. |
|
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| Individual whose information we lawfully obtain from third party partners, only where we have verified that they have the legal basis to share your information with us. | Your full name, email address, phone number, business information, designation, resume, interests, statistical information and any other personal information that you may share on such a public platform. |
|
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If you provide us with any personal information relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this privacy notice. If you believe that your personal information has been provided to us improperly, please contact us by using the information in the “HOW CAN YOU CONTACT US ABOUT THE NOTICE?” section.
In addition to the details provided in the table above, we may also share your personal information with
a. an entity to which we divest all or a portion of our business, or otherwise in connection with a merger, consolidation, change in control, reorganization, or liquidation of all or a portion of our business.
b. law enforcement authorities, government authorities, courts, dispute resolution bodies, regulators, auditors, and any party appointed or requested by applicable regulators to carry out investigations or audits of our activities.
c. professional advisors who advise and assist us in enforcing our contracts and policies, handling our claims, effective management of our company, and in relation to any disputes we may become involved in.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
When You visit the Website(s), a cookie banner will be displayed providing additional information about cookies and options to opt-out of non-essential cookies as required by applicable laws. If you choose to remove cookies or reject cookies, this could affect certain features or Services of our Website.
If you are a data subject from the European Economic Area, our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only where it is needed to perform a contract with you, where the Processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you. If we Process personal information with reliance on your consent, you may withdraw your consent at any time by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THE NOTICE”.
We mainly Process your personal information in the United States and India. However, we may transfer personal information outside the United States and India for the purposes referred to in the “HOW DO WE USE YOUR PERSONAL INFORMATION” section. We will ensure that the recipient of your personal information offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.
If you are a resident of the European Economic Area and when your personal information is Processed outside EEA, we will ensure that the recipient of your personal information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of personal information as approved by the European Commission (Article 46 General Data Privacy Regulation, 2016), or we will ask you for your prior consent to such international data transfers.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to Process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further Processing until deletion is possible.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we Process. The measures we use are designed to provide a level of security appropriate to the risk of Processing your personal information. If you have any questions about the security of your personal information please contact us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THE NOTICE?” However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.
We do not knowingly solicit information from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such information from our records. If you become aware of any personal information we may have collected from children under age 18, please contact us at jaipreet@trademo.com
You are entitled to the following rights:
If you are a resident of the EEA, UK, or Switzerland, you are also entitled to the following rights:
In addition to this you also have the right to complain to a data protection authority about our collection and use of your personal information.
If you are resident of EEA the contact details here of the data protection authorities are available here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are resident in Switzerland, the contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
To request to review, update, or delete your personal information, please submit a request form by sending an email to our data protection authority whose contact information is provided below. We will respond to your request within 30 days.
We will verify any requests before acting on the request and respond to all requests we receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
SHINE THE LIGHT LAW:
“Shine the Light Law” of Civil Code § 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
CALIFORNIA CONSUMER PRIVACY ACT:
This section applies only to California residents and the personal information we collect as a business. “CCPA” means the California Consumer Privacy Act of 2018 as amended by the CPRA. “CPRA” means the California Privacy Rights Act. For the purposes of this section, the terms “business”, “business Purpose”, “consumer” “personal information”, “sale/sell”, “service provider” and “sensitive personal information” and “share” shall have the meaning given to them under the CCPA.
If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted information that you publicly post on the Website. To request removal of such information, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the information is not publicly displayed on the Website, but please be aware that the information may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history and financial information | YES |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
| D. Commercial information | Transaction information, purchase history, financial details and payment information | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from other personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | NO |
We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:
Disclosure of Personal Information: We have disclosed the categories of personal information listed above for a business purpose in the twelve (12) months prior to the Effective Date and may disclose such personal information to service providers or contractors or to any other third parties who support our business provided (a) they do not sell or share such personal information or (b) retain, use or disclose such information for any purpose other than for the specific purpose of performing the Services specified in our contract with them or (c) combine such information with any other information received directly by them. We do not sell or share personal information without providing you the right to opt out. We do not sell or share the personal information of minors. We shall not disclose further the personal information collected for verification of a consumer’s request or retain it longer than it is necessary for the purpose of verification.
Your rights with respect to your personal information
Right to request deletion of the information - Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information and will also instruct our service providers and contractors to delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any Processing that may be required to protect against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual information to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification Process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
This privacy notice is only applicable to the personal information collected from you for the purposes mentioned under the Section HOW DO WE COLLECT, USE, AND SHARE YOUR PERSONAL INFORMATION?
We may receive your personal information from social media platforms, in case you choose to register for our Services through these platforms. We do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.
We may receive your personal information from third-party data vendors to perform our Services. We will make sure that such personal information has been collected on a legitimate basis. Though, it is the responsibility of the third-party data vendors to ensure that it has all the necessary authorizations and approvals to transmit such personal information to us. We shall not be responsible for any unauthorized transfer of such personal information by third-party vendors.
We may receive your personal information from our Customers as part of the Customer Data in order to perform our Services. We only act as a processor in relation to such personal information. In such instances, your data privacy questions and requests should be submitted to the Customer in its capacity as a controller. We are not responsible for Customers’ privacy or security practices which may be different from this notice. Customers are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements, or other obligations, relating to the collection of personal information in connection with the use of the Services.
Our Website contains links to other websites. Our privacy notice applies only to our Website, so if you click on a link to another Website, You should read their privacy policy. We encourage you to review the privacy statements of any such other websites to understand their personal information practices.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Jaipreet Kaur, by email at jaipreet@trademo.com , or by post to:
Trademo Technologies Inc.
Jaipreet Kaur
3000 El Camino Real
Building 4, Suite 200
Palo Alto, CA 94306
United States
You can exercise your rights under this notice by contacting us at customersuccess@trademo.com