Personally Identifiable Information that we collect:
We do not collect personally identifiable information from you on the Web site unless you voluntarily provide it to us, such as by contacting us about an event, inquiring about a job or otherwise choosing to share your personally identifiable information with us. The personally identifiable information which you may provide to us could include your name, email address, physical address and other personal information including your resume and associated information.
Information Collection and Use
We only use your personally identifiable information as described below, unless you have specifically consented to another type of use, either at the time the personally identifiable information is collected from you or through some other form of consent from you or notification to you.
- If you click “HELLO” email address and are inquiring either as a brand or agency representative or as a member of the press/media, we may use your personally identifiable information to respond to your inquires or to send you emails from time to time.
- If you click “HELLO” email address and are inquiring as an event organizer, we may use your personally identifiable information in connection with entering your event into our database and sharing the event information with third parties in connection with the promotion or operating of such event.
- If you click “CAREERS” email address, we may use your personally identifiable information to respond to your job enquiry, and may enter your personally identifiable information in our job database maintained by a third party vendor.
- We may permit our vendors and subcontractors to access your personally identifiable information (including as described above in connection with a job enquiry), but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.
- We may disclose personally identifiable information as required by law or legal process.
- We may disclose personally identifiable information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for the Web site.
- We may transfer your personally identifiable information in connection with the sale or merger of TRO or the division responsible for the services with which your personally identifiable information is associated.
- We may share your personally identifiable information if necessary to respond to your specific requests.
TRO Hosted sites and Affiliate or Subsidiary hosted sites
- If you agree to allow TRO or one of its affiliates or subsidiaries to contact you through a site hosted by TRO or the applicable affiliate or subsidiary and are inquiring either as a brand or agency representative or as a member of the press/media, TRO or the applicable affiliate or subsidiary may use your personally identifiable information to respond to your inquires or to send you emails from time to time.
- If you agree to allow TRO or one of its affiliates or subsidiaries to contact you through a site hosted by TRO or the applicable affiliate or subsidiary and are inquiring as an event organizer, TRO or the applicable affiliate or subsidiary may use your personally identifiable information in connection with entering your event into the applicable database and sharing the event information with third parties in connection with the promotion or operating of such event.
- If you agree to allow TRO or one of its affiliates or subsidiaries to contact you through a site hosted by TRO or the applicable affiliate or subsidiary as part of a job enquiry, TRO or the applicable affiliate or subsidiary may use your personally identifiable information to respond to your job enquiry and may enter your personally identifiable information in a job database maintained by a third party vendor.
- If you submit your personally identifiable information through a site hosted by TRO or one of its affiliates or subsidiaries, TRO or the applicable affiliate or subsidiary may share your personally identifiable information with other TRO affiliates or subsidiaries to the extent necessary to respond to your specific request.
- TRO or an applicable affiliate or subsidiary may permit vendors and subcontractors to access your personally identifiable information (including as described above in connection with a job enquiry), but they are only permitted to do so in connection with performing services for TRO or the applicable affiliate or subsidiary. They are not authorized by to use the information for their own benefit.
- TRO or an applicable affiliate or subsidiary may disclose personally identifiable information as required by law or legal process.
- TRO or an applicable affiliate or subsidiary may disclose personally identifiable information to investigate suspected fraud, harassment or other violations of any law, rule or regulation, or the terms or policies for the Web site.
- TRO or an applicable affiliate or subsidiary may transfer your personally identifiable information in connection with the sale or merger of TRO Marketing or the applicable affiliate or subsidiary or the division responsible for the services with which your personally identifiable information is associated.
- TRO or an applicable affiliate or subsidiary may share your personally identifiable information if necessary to respond to your specific requests.
Visitors to any specific program web sites built for our clients may be given the option of providing contact information and other personally identifiable information, such as their name and email address. This information may be used by us to enter the visitor in a promotion, provide information, assess the needs of a business to determine suitable products and select and contact potential winners and other site visitors via phone, fax, email and paper mail.
When we receive, collect and process consumers’ personally identifiable information in connection with a program, we may also require sensitive information, such as social security number or date of birth. Visitors may provide this information in a variety of methods, depending on the particular promotion. We only use this personally identifiable information to conduct the program for the applicable client, in order to select winners, award other prizes or bonuses or for the other purposes of the program. We do not use the information for any other purpose. We maintain the information only for so long as necessary to verify and conduct the program and to provide redundancy for our clients. We do not provide this information to any entity other than our client and others involved in the operation of the promotion. Our clients’ privacy policies govern the use of this data and it remains their property. Any exceptions to these procedures will be announced in connection with the program for which the change is made.
We also process personally identifiable information we receive directly from our clients. In these cases, anyone who seeks access to or wishes to correct, amend, delete inaccurate data or withdraw consent of further contact should direct their query to the applicable client or sponsor. If the applicable client requests that we remove the data, we will respond to such request within 30 days.
It is our policy to retain client data, including personal identifiable information necessary for the selection, notification and awarding of prizes in promotions and any tax forms that are legally required to be completed for awarding those prizes, for only as long as legally required or as requested by the applicable client, whichever is longer. No personal data is collected other than that required to select, notify and award a prize winner per applicable law. All physical documents are shredded and disposed of by a secure data disposal service. All electronic data is deleted and removed from all electronic devices including backups on a monthly deletion schedule. All requests from clients for data to be retained longer than legally required or transferred to them or another vendor must be made in writing and in advance.
We also collect certain information, not personally identifiable, on the Web site and in connection with the Programs. We may collect information about your computer configuration such as your browser type, operating system, or ISP domain name. We may collect information about the site you last visited prior to your participation in the program or about your activity during your visit to the applicable program site. We may also offer social sign on services that allow you to register for a promotion using a third party social networking site such as Facebook, YouTube, Google or Twitter. By using these services you allow us to access the available information from your third party social network profile such as your name, age, gender, location, email address and list of friends. We may use this information to administer the technical and operational aspects of the Web site or the applicable program site, and may include using your IP address to help diagnose problems with our server. Your IP address may also be used to gather broad demographic information for aggregate use. This helps us to safeguard the program and diagnose problems in the operation of a promotion.
We may also use “Cookies.” A cookie is a small text file that is stored on a user’s computer for recordkeeping purposes. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A session cookie might be used to track a user through a multipage registration process so they would not have to re-enter information multiple times during the registration process. A persistent cookie remains on your hard drive for an extended period of time. For example, we may set a persistent cookie for a day to prevent a user from returning to a site and trying to enter a Sweepstakes more than once a day. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. Each browser has a function which enables the user to disable cookies if so desired, but in that case, the participant may not be able to participate fully in a promotion, and certain aspects of our site may be limited. We also gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyse trends, track users’ movements and to gather demographic information about the user base of both our client’s promotions and our website. We do not link this automatically collected data to personally identifiable information.
Sharing your Information
We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.
We may also disclose your personal information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; to any other third party with your prior consent to do so. If TRO is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Access and Choices Regarding Your Data
Upon request you may view and have inaccuracies corrected in contact information or other personally identifiable information, by sending us an email to firstname.lastname@example.org with “Contact Correction” written in the subject line and the correct information written in the body of the email, or you may mail us your request to the address below. We will respond to your request to access within 30 days.
If you have provided us with contact information or other personally identifiable information and do not want to receive email from TRO in the future and wish to delete such information, please let us know by sending an email to email@example.com with “Remove from List” written in the subject line, or you may mail us your request to the address below.
When you provide personal information to us through our website, we will retain your information as needed to provide you services and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Please note that you are responsible for providing accurate and complete personally identifiable information and for contacting us if corrections are required.
The security of your personal information and our Client’s information is important to us. When sensitive information (such as a social security number) is entered in our promotion and sweepstakes forms, we encrypt the transmission of that information using secure socket layer technology (SSL).
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at firstname.lastname@example.org.
Other Privacy Information
Our Web site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Behavioral Targeting / Re-Targeting
Special Note about Children
We abide by the Children’s Online Privacy Protection Act (“COPPA”). We will not knowingly allow anyone under 13 to provide any personally identifiable information through the Web site or in connection with any Programs without the appropriate parental authorizations.
Your California Privacy Rights (As provided by California Civil Code Section 1798.83)
We may transfer the personal information we collect about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to recipients in other countries (such as the U.S.), we will protect that information as described herein.
If you are located in the European Economic Area (“EEA”) or Switzerland, we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside of the EEA or Switzerland. With respect to transfers of personal information to the U.S., TRO is certified under the EU-U.S. and Swiss-U.S. Privacy Shield frameworks developed by the U.S. Department of Commerce and the European Commission regarding the transfer of personal information from the EEA or Switzerland to the U.S.
United States of America:
Our Web site is maintained in the United States of America. By using the Web site, you freely and specifically give us your consent to export your personally identifiable information to the USA and to store and use it in the USA as specified in this policy.
Privacy Officer: TRO Group, 85 The Strand, London WC2 R0DW
We can be reached via email at: firstname.lastname@example.org.
We encourage you to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information in accordance with our internal policies. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution through our chosen third-party resolution provider, JAMS.
Last revised on April 12, 2018