Information We Collect About You
We may obtain your Personal Information when you:
- Use our website or applications;
- Request quotes, services, support, downloads, trials, whitepapers, training or information;
- Participate in surveys or other promotional activities online or in any other venue;
- Place orders for products or services;
- Register for events or webinars;
- Create and manage an account;
- Subscribe to newsletters, marketing and promotional emails or other materials;
- Contact us.
Categories of Personal Information we collect may include your name, email address, address, contact telephone numbers, user ID, and password. It may also include work information such as job title and other business or company information. Forms that you choose to complete will indicate whether information requested is mandatory or voluntary.
In order to offer you a more consistent and personalized experience in your interactions with TrustNet, information collected through one source may be combined with information TrustNet obtains through other sources. This may include information that allows us to identify you across multiple devices through which you access our website. We may also supplement the information we collect with information obtained from other parties, including our Business Partners and other third parties to create customized profiles about you. Examples of how we may use this information include using your data to help us to improve your experience using our website, to present you with options tailored to your preferences and for targeted advertising purposes as explained below.
Some TrustNet services may be co-branded and offered in conjunction with another company. If you register for or use such services, both TrustNet and the other company may receive information collected in conjunction with the co-branded services, and may use the information according to each company’s privacy statement and other agreements with you.
Information We Automatically Collect
We may automatically collect behavioral and usage information about your visits to our website, including the pages you view, the links and advertisements you click, search terms you enter, and other actions you take in connection with TrustNet website and services. We may also collect certain information from the browser you use to come to our website, such as your IP address, device identifier, location data, browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our website and the URL to which you browse away from our website if you click on a link on our website.
Information From Third Party Sources
We may obtain information about you from third party sources such as public databases, our Business Partners, joint marketing partners and social media platforms. An example of the information we may receive from other sources includes page-view information from some Business Partners with which we operate co-branded services or joint offerings. We may use the information to better understand you, to enhance our ability to provide relevant marketing of products and services to you, and to help prevent and detect fraud.
Information We Collect When Providing Services
We may obtain Personal Information in the course of providing products and services to our corporate customers (such as IP addresses, MAC addresses, usernames, email addresses, customer contact information). TrustNet is the controller of any Personal Information contained within records or logs of security events (“Security Event Data”) that are identified and collected during the provision of customer services. If you work for a corporate customer that uses our services, it is possible that Personal Information about you may be contained in Security Event Data processed by TrustNet. We will use such information for the purpose of providing the services and in order to develop, enhance and/or improve our security products and services that we offer and provide to our other customers. We will comply with applicable laws in respect of any Personal Information contained within the Security Event Data and have in place measures to safeguard such information to the standard required by law.
How We Use Personal Information
TrustNet may use your Personal Information to:
- Carry out the transaction that you have requested;
- Deliver our products, solutions, services and support, or detecting security incidents;
- Send communications to you about products and services available from TrustNet and its subsidiaries, including information about particular TrustNet programs in which you or your company has chosen to participate, as well as events, promotional offers and surveys;
- Facilitate communications from TrustNet’ Business Partners;
- Customize, analyze and improve our products, solutions, services (including the content and advertisements on our website to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you;
- Better understand our customers and online users based on interest and interactions with our website;
- Personalize content and implement your preferences;
- Enforce our contracts with customers and our website terms and conditions;
- Prevent fraud and other prohibited or illegal activities;
- Protect the security or integrity of our website, our businesses and our products or services; or
- Perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.
Legal Basis for Processing
Our legal basis for collecting and using your Personal Information as described in this Privacy Statement will depend on the Personal Information concerned and the specific context in which we collect it. In general, we collect and process your Personal Information on one or more of the following bases:
- For compliance with TrustNet’ legal obligations where other laws require the processing of your Personal Information (for example, health and safety, taxation and anti-money laundering laws) or where we need your Personal Information to protect your vital interests or those of another person.
- TrustNet’s and its Business Partners’ legitimate interests which include the provision of our website and/or relevant products and services, and/or the carrying out of marketing and profiling activities, provided always that our legitimate interests are not outweighed by any prejudice or harm to your rights and freedoms.
If you have any questions or need more information concerning the legal basis on which we collect your Personal Information, please contact us at [email protected]
Retention of Your Personal Information
We will retain your Personal Information as necessary in connection with the purposes described in this Privacy Statement and in accordance with TrustNet’ retention policies and applicable law.
TrustNet may transfer your Personal Information to other companies within the TrustNet group and/or to its Business Partners, if required for the purposes described in this Privacy Statement. This may involve the transfer of your Personal Information to countries outside your home country or region, including outside the European Economic Area if that is your region, which may have a different level of data protection from your home country. Such countries may include, without limitation, the United States and other countries in which TrustNet or its subsidiaries, our subsidiaries and affiliates, or Business Partners maintain facilities (see the bottom of this Privacy Statement for a list of our affiliates). In order to provide adequate protection for the transfer of your Personal Information, we have in place contractual arrangements (as appropriate) with our subsidiaries, affiliates and Business Partners in respect of such transfers (based on EU Commission approved standard contractual clauses). We will take all reasonable technical and organizational measures to safeguard Personal Information we transfer in accordance with applicable laws.
How We May Share Your Personal Information
We may share your Personal Information with other TrustNet entities (see the bottom of this Privacy Statement for a list of our affiliates and subsidiaries) as well as Business Partners for the purposes described in this Privacy Statement, including (without limitation) to carry out transactions you request, or to make our business (or that of our subsidiaries and affiliates) more responsive to your needs. We will only share your Personal Information with TrustNet affiliates and subsidiaries and Business Partners who agree to protect your Personal Information and use it solely for the purposes specified by TrustNet.
In addition, TrustNet may share your Personal Information with participants in our sales and marketing chain, including but not limited to retailers, resellers, distributors, integrators, order fulfillers and some sales agents and resellers/channel partners, for the limited purposes of selling, marketing or providing support for TrustNet products and services.
We may disclose your Personal Information for any purpose with your consent.
We may also disclose your Personal Information in connection with law enforcement, fraud prevention or other legal action; as required by law or regulation; if TrustNet (or a part of TrustNet) is sold or merges with another company; or if TrustNet reasonably believes it is necessary to protect TrustNet, its customers or the public.
Notice to California Residents – Your California Privacy Rights
If you are a California resident, in addition to the rights listed in the “Selecting Your Communication Preferences, Opting Out of Marketing and Profiling” section below, you have certain rights, pursuant to the California Consumer Privacy Act of 2018 (CCPA). These CCPA rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. You can exercise these rights using the contact details below.
Right to Know
As a California resident, you have the right to request that we disclose what Personal Information we collect, use, disclose and/or sell.
Right to Request Deletion
As a California resident, you have a right to request the deletion of your Personal Information collected or maintained by us.
Right to Non-Discrimination
As a California resident, you have a right not to receive discriminatory treatment by us for the exercise of any of your CCPA rights.
As a California resident, you can exercise your CCPA rights or you can designate an authorized agent to make a request on your behalf. We may require that you provide the authorized agent written permission to submit a request on your behalf and that the authorized agent verifies their own identity directly with us.
Contact Us for More Information
If you have questions about this Privacy Statement, including anything in this section about your CCPA rights, please contact us at [email protected]
You have the right to know whether your Personal Information is being sold. Your Personal Information is sold when it is shared with a third party for monetary or other valuable consideration for a purpose that is not a “business purpose” as set forth within the CCPA.
We do not sell your Personal Information and have not sold your Personal Information in the preceding 12 months. For this reason, we have not included an opt-out of sale of your Personal Information.
Personal Information that We Collect
In addition to the information that can be found in the “Information that We Collect About You”, “How we Use Personal Information” and “How We May Share Your Personal Information” sections of this Privacy Statement, the table below summarizes the categories of Personal Information that we collect, the sources of the information, the purpose for which it was collected and the categories of third party recipients with whom we may share Personal Information.
Categories of personal information
Sources of personal information
Business or commercial purpose for which it was collected
Identifiers (name, job title, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, passwords)
Directly from you; via our service providers (including our Business Partners); via public databases, via our affiliates or subsidiaries;
For our operational purposes, including performing services; fulfilling or meeting the reason you provided the information, providing customer service; providing advertising or marketing services; detecting security incidents; and preventing or detecting fraud and other prohibited or illegal activity.
Service Providers, subsidiaries and affiliates
Internet or other electronic network activity (browsing history, search history, location data, information regarding your interaction with the Site or advertisements)
Directly from you; via our service providers (including our Business Partners); via our affiliates or subsidiaries
For our operational purposes, including performing services; better understanding our customers and online users based on interest and interactions with our website; personalizing content and implementing your preferences; enforcing our website terms and conditions; and preventing or detecting fraud and other prohibited or illegal activity.
Service Providers, subsidiaries and affiliates
Personal information collected when providing services (personal information within raw logs and Security Event Data such as IP address, MAC addresses, usernames, email addresses, device identifiers, user account information)
Directly from our customers and/or customer or third party devices that we monitor during the provision of services
For our operational purposes, including delivering products, solutions, services and support; detecting security incidents; preventing or detecting fraud and other prohibited or illegal activity; developing, enhancing and/or improving the security services and products that we offer.
Service Providers involved in the provision of services, subsidiaries and affiliates
Submitting a Consumer Request
To submit a verifiable consumer request, you or your authorized agent can do so by sending a written request to [email protected] or to the postal address provided at the bottom of this Privacy Statement. You can also call our toll-free number below..
Phone: +1 877-878-7810
You may only make a verifiable consumer request to know twice within a 12-month period. We may ask for certain information to verify the request in accordance with applicable law. The verifiable consumer request to know and request for deletion must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you would like to print a copy of this Privacy Statement, please select the “Print” button in your web browser.
Your EU Data Protection Rights
Where the processing of your Personal Information is subject to EU data protection laws, you have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law:
- Access: you have the right to request information about how we process your Personal Information and to obtain a copy of that Personal Information
- Rectification: you have the right to request the rectification of inaccurate Personal Information about you and for any incomplete Personal Information about you to be completed.
- Objection: you have the right to object to the processing of your Personal Information which is based on our legitimate interests (as described above).
- Erasure: you have the right to request the erasure of your Personal Information (subject to certain conditions).
- Automated decision-making: you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
- Restriction: you have the right to ask us to restrict our processing of your Personal Information, so that we no longer process that information until the restriction is lifted.
- Portability: you have the right to receive your Personal Information, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organization in certain circumstances.
In addition to the above, you have the right to lodge a complaint with a supervisory authority (such as the supervisory authority in your member state of habitual residence, place of work or where the alleged infringement took place) if you consider that our processing of your Personal Information infringes applicable data protection law.
If you have any questions about the type of Personal Information we hold about you or if you wish to request deletion or correction of Personal Information we hold about you, or exercise any other data subject right, please send a written request to [email protected] or to the postal address provided at the bottom of this Privacy Statement. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.
Selecting Your Communication Preferences, Opting Out of Marketing and Profiling
You may choose to receive or not receive marketing communications from TrustNet by indicating your preferences. Opportunities to select your preferences include the following:
- Contact us at [email protected]rustNetInc.com if you have questions regarding communication preferences, our marketing activities and/or profiling
- You can click “unsubscribe” in any marketing email communications we send you, or by sending us an email at [email protected];
Any marketing by TrustNet, or any third parties on behalf of TrustNet, will be conducted in accordance with applicable laws and include (where applicable) methods to allow you to express your preferences (including the possibility of being removed from our advertising and marketing lists as set out above).
Please allow up to 10 business days for your email preferences to take effect. As some promotions are developed in advance, you may sometimes receive marketing communications after we receive your preference request. If you opt out of receiving marketing communications, we may still communicate with you in connection with transactions you request and/or service related matters.
How We Secure Your Personal Information
TrustNet takes all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorized access, modification or disclosure. The ways we do this include:
- using encryption in transit when collecting or transferring sensitive information
- having in place technical and organizational measures designed to ensure the ongoing integrity, availability and resilience of processing systems and services;
- limiting physical access to our premises;
- limiting access to the information we collect about you;
- ensuring that we and our Business Partners have appropriate security safeguards to keep Personal Information secure; and
- where required by law, destroying or de-identifying Personal Information.
We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from TrustNet asking for your Personal Information. TrustNet will not request your ID or password through email.
Collection and Use of Children’s Personal Information
Our website is not intended for use by children under the age of 13. We do not knowingly collect personal information from children under the age of 13 through our website. If you are under 13 years of age, please do not submit any Personal Information through our website without the express consent and participation of a parent or guardian. If we learn that we have collected the personal information of any such individual, we will take steps to delete the information as soon as possible.
A cookie is a piece of text that is placed on your computer’s hard drive. Depending on the settings you have selected, your browser adds the text to your device as a small file. Many browsers are set to accept cookies by default. You have the ability to customize your cookie settings on the TrustNet website by visiting the cookie “Privacy Preference Center” which can be found by clicking the “Cookie Settings” link in the cookie banner.
Cookies allow you to take advantage of some of our website’s essential features. If you choose to decline cookies, you may not be able to sign in or use other interactive features of TrustNet website and services that depend on cookies.
Targeted Display Advertising by TrustNet and Others
“Do Not Track” Signals
Targeted Email Marketing by TrustNet
Some marketing you receive, including email marketing, may also be personalized based on your visits to TrustNetInc.com and your browsing history. In addition, when you click on some links in email marketing you receive, our email service provider may place a cookie on your browser. This type of cookie would be linked to your email address or IP address and used to gather information about the products and services you view and access on TrustNetInc.com. Information gathered may be used to personalize and customize future email marketing messages you receive. You may opt out of this use by clicking on the unsubscribe link provided in every personalized email marketing message you receive.
How We and Our Partners Use Web Beacons, Pixel Tags and Tracking Technology
TrustNet or its Business Partners may use web beacons on our website, in our email messages, in our advertisements on other websites, or in our advertisements in others’ email messages.
A web beacon is an electronic image that can be used to recognize a cookie on your computer when you view a web page or email message. Web beacons help us measure the effectiveness of our website and our advertising in various ways. For example, web beacons may count the number of individuals who visit our website from a particular advertisement or they may tell us when a web page is viewed and provide a description of the page where the web beacon is placed. Web beacons may also measure the effectiveness of our email campaigns, by counting the number of individuals who open or act upon an email message, determining when an email message is opened and determining how many times an email message is forwarded. Subject to local laws, we may combine the information that we collect through web beacons with other Personal Information we have collected from you.
We may allow some of our Business Partners to compile individual or aggregated statistics from the use of web beacons on TrustNetInc.com by TrustNet, its agents or others, to determine the effectiveness of online marketing and to develop statistics on how often clicking on an advertisement results in an action on the advertiser’s site. Aggregate information may include demographic and usage information. No Personal Information about you is shared with Business Partners for this research.
When you visit our website or view one of our email messages, we may use pixel tags (also called “clear” gifs), tracking links and/or similar technology to note some of the pages you visit on our website. We may also use pixel tags to determine what types of email your browser supports. We may use the information collected through web beacons, pixel tags, tracking links and similar technology in combination with your Personal Information to personalize your experience on TrustNetInc.com and to provide you with more useful and relevant advertisements.
Social Media Features
Links to Third-Party Websites and Services
Please be aware that TrustNet provides links to other websites, which if you click on them may collect Personal Information about you. The information practices of those third-party websites linked to TrustNetInc.com are not covered by this Privacy Statement
Changes to This Privacy Statement
We will occasionally update this Privacy Statement. If we make changes to this Privacy Statement or make any material changes to how we use your Personal Information, we will revise this Privacy Statement to reflect such changes and revise this Privacy Statement’s effective date, included at the end of this section. We encourage you to periodically review this Privacy Statement to be informed of how we are using and protecting your Personal Information.
List of Affiliates
iTrust Holdings Inc.
1155 Mt Vernon Highway, Suite 800
Atlanta, Georgia 30338
TrustNet Assurance Services LLC
2615 Columbia Pike, Suite 286
Arlington, VA 22204
If you would like to contact us for any reason regarding our privacy practices, please email us at [email protected] or write to us at the following address:
TrustNet (Aspire Alliance LLC).
Attn: Privacy/Legal Department
1155 Mt Vernon Highway, Suite 800
Atlanta, Georgia 30338
Effective Date: November 14, 2019.
Last Updated: August 1, 2020