Dated: 15 May 2018
PLEASE READ THIS POLICY CAREFULLY
Protecting your personal information is very important to Trint Limited (“Trint Limited” “our”, “us” or “we”).
Our Website may contain links to third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third-party websites.
Identity and contact information of the Data Controller
For the purposes of data protection legislation in the European Union, the data controller (i.e. the person that determines the purposes and manner in which your personal data are processed) is Trint Limited. Trint Limited is a company incorporated and registered in England and Wales (company number 09225083) with its registered office at Jag Shaw Baker Berners House, 47-48 Berners Street, London, England, W1T 3NF, United Kingdom.
Personal information we may process about you
Our Website operates primarily to market the Platform to individuals and organisations. To the extent we collect personal data via our Website, our main purpose is to better serve our potential customers and to improve the function of the Website. A breakdown of the personal data we may process is set out in the table below.
|Personal data||Why are personal data processed?||Legal basis for processing||Period for which your data will be stored||Will your personal data be shared with third parties?||Transfers outside the European Economica Area|
|1.||The IP address or other unique identifier of the device you used to access our Website.||To improve the function of the Website.||Processing is necessary for our legitimate interests (i.e. to understand who is visiting the Website).||3 years||For analytics and error tracking purposes, may share this data with organizations such as Mixpanel Inc., Twitter Inc., Microsoft Corp., Google LLC and Facebook Inc. or their or its affiliates. This helps us improve our Website.||Mixpanel Inc., Twitter Inc., Microsoft Corp., Google LLC and Facebook Inc. or their or its affiliates may store and process this data in the USA. To ensure these transfers are lawful, we rely on the fact that each entity is certified as complying with the EU-US Privacy Shield regime. In the event they are not certified by the EU-US Privacy Shield regime, we will ensure another lawful mechanism exists.|
|2.||Usage data (e.g. information about how you use our website) and other technical data (e.g. browser type and version, time zone setting and location).||To improve the function of the Website.||Processing is necessary for our legitimate interests (i.e. to understand who is visiting the Website).||3 years||We may share this data with organizations such as Mixpanel Inc. for analytics and error tracking purposes. This helps us improve our Website.||Mixpanel Inc. stores and processes this data in the USA. To ensure this transfer is lawful, we rely on the fact that Mixpanel Inc. is certified as complying with the EU-US Privacy Shield regime.|
|3.||Your first name, last name, email address, postal address and company name.||To enable us to engage in direct marketing (such as newsletters or marketing emails for products and services provided by us that we believe will be of interest to you).||Processing is necessary for our legitimate interests (i.e. direct marketing activities to customers and potential customers).||Until such time as you inform us you don’t want to continue receiving marketing communications – you have the right to unsubscribe at any time.||We use third party CRM or analytics providers such as HubSpot Inc. to manage our sales and marketing activities.||HubSpot Inc. stores and processes personal information in the USA. To ensure this transfer is lawful, we rely on the fact that HubSpot Inc. is certified as complying with the EU-US Privacy Shield regime.|
|4.||A record of any communication / correspondence you have with us (e.g. when you contact us by email, telephone or post).||To enable us to maintain records with our potential and actual clients.||Processing is necessary to take steps at your request prior to entering into a contract.
If this doesn’t apply, then you have provided your consent.
|For up to 6 years||We may use third party hosted services such as Google to manage our activities.||We may use hosted services (such as Google) which stores and processes personal information in the USA or elsewhere. Where we do so, we will ensure that the transfer is lawful.|
|5.||Any personal data that you provide to us as part of a survey.||To improve our Website or services.||Processing is necessary for our legitimate interests (i.e. to understand the requirements of our potential and actual clients).||For as long as we are using such data to improve our services and for a reasonable period afterwards.||We may use third party hosted services such as Google to manage our activities.||We may use hosted services (such as Google) which stores and processes personal information in the USA or elsewhere. Where we do so, we will ensure that the transfer is lawful.|
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Where we send electronic marketing communications we will provide an option to unsubscribe or opt-out of further communication, or you may opt out by contacting us at firstname.lastname@example.org.
We will not sell your personal data (or any other data you provide us with) to third-parties for marketing purposes.
How personal data are collected
We may obtain personal data about you in two main ways:
Where we store your personal information
The personal data that we collect from you is likely to be transferred to and stored at a destination outside of the European Economic Area (“EEA”). This data may also be processed by staff operating outside of the EEA who work for us or for one of our business partners or service providers. Further information is provided in the table above. Please contact us at email@example.com if you would like further details on the specific safeguards applied to the export of your personal data outside the EEA.
Disclosure of your information
We may also disclose your personal information to third parties in the following circumstances:
|Purpose of disclosure and third party(s) to which disclosure might be made||Use justification|
|If you request we do so||You have provided your consent|
|If Trint Limited or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets.||Legitimate interests (i.e. to dispose of our business).|
|If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Trint Limited, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.||Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person.|
|We may disclose your personal information to third parties, the courts and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where we are compelled or believe it is reasonable to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.||Processing is necessary for compliance with a legal obligation, or processing is necessary in order to protect the vital interests of a natural person.
Alternatively, legitimate interests (i.e. to cooperate with law enforcement and regulatory authorities).
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at firstname.lastname@example.org.
You have the following rights in relation to your personal data:
|Rights of Access||You have the right to obtain from us confirmation as to whether your personal data are being processed, and, where that is the case, access to such personal data.|
|Right to Rectification||We will use reasonable endeavors to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.|
|Right to erasure / ‘Right to be forgotten’||Asking us to delete all of your personal data will result in us deleting your personal data without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal data, in which case we will inform you of this in writing).|
|Right to restriction of processing||You have the right to ask us to stop processing your personal data at any time.|
|Right to data portability||You have the right to request that we provide you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.|
|Right to complain||You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints.|
We will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs.
Where you request us to rectify or erase your personal data or restrict any processing of such personal data, we may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example to comply with its legal obligations.
Children under the age of 16
The Website is not aimed at children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, please do not use our services or provide any information to us through the Website. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at email@example.com.
Changes to this policy