Data Privacy Notice

This Data Privacy Notice explains how Trapp Technology uses and protects information that could be used to identify you or other individuals (“Personal Data”).

CONTROL OF CUSTOMER DATA

Trapp technology will be the controller of any Data a Customer provides via the Service Desk IT support processes or company Website access. Trapp Technology is located at 2600 N. Central Ave, Suite 1100, Phoenix, AZ, U.S.A. Trapp’s Chief Information Security Officer can be reached at the U.S. address above, or at privacy@trapptechnology.com.

WHAT PERSONAL DATA WILL BE COLLECTED

Trapp Technology collects Personal Data on its websites when you request services or other information, sign up for on-line or physical events, apply for jobs or participate in surveys. We collect Personal Data that you provide (such as names, mailing addresses, email addresses and telephone numbers) and Personal Data that are not directly entered such as machine names and IP addresses. We also may receive Personal Data at meetings, through emails, on telephone calls, and during Chat sessions. We do not collect sensitive Personal Data, such as information relating to health, race, ethnicity, sexual orientation, or trade union membership, except that we collect health information as needed to administer employee benefits, and we may collect other sensitive information from employees or applicants if required to show compliance with fair hiring and employment laws. We do not collect or store credit card data. You may enter such data into the system of an independent credit card processor, but it is not accessible to or stored by Trapp Technology. Our services are not directed at people under the age of eighteen, and we request that they not provide us any Personal Data. We will erase any such data that is inadvertently provided or stored.

HOW YOUR PERSONAL DATA WILL BE USED

Trapp Technology will only collect, store, use or otherwise process your Data for the following purposes:

Prepare for or perform contracts for the sale of Trapp Technology’s goods or services
Pursue our legitimate interests in marketing our goods or services, except where those interests are overridden by your interests or fundamental rights
To the extent needed to meet disaster recovery and business continuity obligations
Where required to protect your rights or safety or the safety of others
Comply with judicial or governmental subpoenas, warrants or orders; and, in the unexpected event of a bankruptcy proceeding

Your Personal Data is not shared with, or stored on platforms provided by, third parties (persons or companies who are not part of Trapp Technology). Your Personal Data will not be sold to or otherwise provided to third parties for purposes of marketing their goods or services. Your Personal Data will not be subject to any automated decision-making or profiling that would affect your rights.

HOW LONG YOUR PERSONAL DATA WILL BE RETAINED

Trapp will only retain your Personal Data for the time needed to accomplish the purposes listed above. Trapp Technology has specific data retention and destruction policies which you may request at privacy@trapptechnology.com.

HOW YOUR PERSONAL DATA WILL BE PROTECTED:

Trapp Technology complies with all laws and regulations applicable to it, including data protection laws. Trapp Technology has appropriate technical and organizational measures in place to ensure that your Personal Data:

Processed lawfully, fairly and in a transparent manner
Collected for the purposes specified above and not further processed in a manner incompatible with those purposes
Adequate, relevant and limited to what is necessary for those purposes;
Accurate and where necessary, kept up to date with inaccurate data promptly corrected or deleted
Retained for no longer than necessary for the purposes stated above
Kept secure as per Trapp Technology Information Security policy

YOUR PERSONAL DATA RIGHTS

You have important data rights, including the following:

Right to Withdraw Consent. If you have consented to the use of your Personal Data, you have the right to withdraw consent at any time, and to unsubscribe from all marketing emails.
Right to Access Information and Obtain Rectification. You have the right to access and review your Personal Data and have any errors in it corrected.
Right to Object to or Limit Processing. You have the right to object to the processing of your Personal Data and to restrict or limit direct marketing or other uses.

ADDITIONAL RIGHTS FOR EU CITIZENS AND RESIDENTS

If you are a resident or citizen of the European Union (EU), you will have new data protection rights after the EU’s General Data Protection Regulation (GDPR) takes effect on May 25, 2018, as follows:

Right to Erasure. You have the right to request that Trapp Technology erase all of your Personal Data retained or used by it and to no longer store or otherwise process it.
Right to Data Portability. You have the right to obtain an easily readable and transferrable copy of any Personal Data that is processed by automated means and that you provided to Trapp Technology pursuant to a consent or for performance of a contract.

To exercise any of the above rights, please fill out the form below. Trapp Technology will respond to your request to exercise these rights without delay and within one month.

TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES

Trapp Technology has offices in countries whose data protection laws have not been deemed to be adequate by the European Union (EU), including the United States and it may transfer your Personal Data among those offices. Trapp Technology will not transfer your Personal Data to third parties who assist us in providing or marketing our goods or services, who may be located in countries that do not have data protection laws as strong as those in your own country. To address these risks, Trapp Technology enters into Data Transfer Agreements containing Standard Clauses approved by the EU Commission, which contractually require the level of data protection mandated by the EU.

CHANGES TO OUR DATA PRIVACY POLICY

We regularly review our Information Security Policy and provide updated versions on our Auditors. This Data Privacy Policy was created on April 25, 2018.

HOW TO CONTACT US OR LODGE A COMPLAINT

If you have questions about our Data Privacy Policy or our use or protection of your Personal Data, please contact Trapp Technologies Chief Information Security Officer at privacy@trapptechnology.com or at the U.S. address above. You have the right to lodge a complaint about the treatment of your personal data by contacting the data protection authorities in your home country or by contacting the U.K.’s Information Commissioners office at 0303 123 1113 or https://ico.org.uk/concerns.