(Effective July 15, 2018)
Trade Technologies, Inc. and its subsidiaries. (“Trade Technologies,” “we,” “us,” “our,” or the “Company”) are committed to protecting the privacy of individuals who visit the Company’s Websites (“Visitors”), individuals who use our Services as defined below (“Customer Employees”), and individuals who register to attend the Company’s training events (“Attendees”). This Privacy Statement describes Trade Technologies’ privacy practices in relation to the use of the Company’s Websites and the related applications, services, and programs offered by Trade Technologies (collectively, the “Services”), as well as individuals’ choices regarding use, access and correction of personal data.
1. Contact Details
If you have questions or complaints regarding Trade Technologies’ Privacy Statement or associated practices, please contact us as follows:
The responsible data controller is:
Trade Technologies, Inc.
4601 Spicewood Springs Road, Suite 3-100
Austin, Texas, 78759 USA
The phone number of our Austin, Texas headquarters:
You can reach our Data Protection Officer at email@example.com or by writing to the Data Protection Officer at the above address.
2. Websites Covered
This Privacy Statement covers the information practices, including how the Company collects, uses, shares and secures the personal data you provide, of the Company’s Websites (collectively referred to as “Trade Technologies’ Websites” or “the Company’s Websites”) including the Company’s TradeSharp Websites and the Company’s Marketing Websites. The Company’s TradeSharp Websites include multi-tenant and private cloud versions of the TradeSharp software utilized by the Company to provide, and its customers and third parties to access, the Company’s Services, including, but not limited to ddm.tradetechnologies.com, tradesharp.tradetechnologies.com, and tradesharp-emea.tradetechnologies.com. The Company’s Marketing Websites including www.tradetechnologies.com and www.trade-technologies.com, are used to provide the public with information and marketing materials about the Company and its Services.
3. Information collected
When expressing an interest in obtaining additional information about the Services, or registering to use the Websites or other Services, or registering for an event, Trade Technologies requires you to provide the Company with personal contact information, such as name, company name, address, phone number, and email address (“Required Contact Information”). When purchasing the Services or registering for an event, Trade Technologies may also require you to provide the Company with billing information, such as billing name and address and credit card number (“Billing Information”). When Visitors apply for a job with the Company, Trade Technologies may also require you to submit additional personal information as well as a resume or curriculum vitae (“Applicant Information”). Required Contact Information, Billing Information, Applicant Information and any other personal information you submit to Trade Technologies to or through the Services are referred to collectively as “Personal Data.”
As you navigate the Company’s Websites, Trade Technologies may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons (“Website Navigational Information”). Website Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Websites (such as the Web pages viewed and the links clicked). Website Navigational Information that can contribute to the identification of a person also constitutes “Personal Data”, as defined above.
4. Purposes of Data Processing
Trade Technologies collects and processes your Personal Data for a variety of purposes.
The Company uses Personal Data about Customers to perform the Services. For example, the Company uses your email address to permit you to login to the TradeSharp Websites. Other Personal Data such as name, phone number and email address may be used to identify, track and record your activities on the TradeSharp Websites and to permit other users, including Trade Technologies employees providing Services, to contact you. The Company also uses Personal Data about Attendees to plan and host training events, host online forums and social networks in which event Attendees may participate.
The Company may also use Personal Data about Visitors, Customers, and Attendees for marketing purposes. For example, if you fill out a web form requesting contact, the Company will use the information provided to contact you about your interest in the Services. The Company may also use the information you provide to follow up regarding your interest in the Services and to send you information regarding the Company and its Services.
Trade Technologies may also receive information about you from other sources, including public websites and possibly third parties, and combine this information with Personal Data we already have about you. This helps us to update our records and determine Services that may be of most interest to you.
Trade Technologies uses credit card information solely to collect payment from prospective Customers and Attendees.
Trade Technologies uses Website Navigational Information to operate and improve the Company’s Websites. The Company may also use Website Navigational Information alone or in combination with Personal Data about Visitors, Customers, and Attendees to provide personalized information about the Company.
5. Legal Grounds of Data Processing
If you are a citizen of the European Economic Area (EEA), the processing of your Personal Data is based on the following legal grounds:
Performance of a contract – When Trade Technologies needs to process your Personal Data to enter into a contract with you or your employer or to perform a contract that you or your employer may have with us, the processing is based on Article 6, section 1 (b) GDPR. For example, when you use our Services, we will use your Personal Data to respond to your requests and provide you with access to the Services.
Consent – When we process Personal Data based on your consent, the legal grounds for processing is Article 6 section 1 (a) GDPR.
Legal obligation- When the processing of Personal Data is necessary for compliance with a legal obligation to which we are subject, the processing is based on Article 6 section 1 (c) GDPR.
Legitimate interests – We may process your Personal Data for our legitimate interests, e.g. to improve our Services and to provide you with relevant information including information for marketing purposes. When we process your Personal Data based on our legitimate interests, the legal grounds for such processing is Article 6, section 1 (f) GDPR.
If you are not a citizen of the EEA, please contact us or our Data Protection Officer for details on the legal grounds of data processing. You find our contact details above.
6. Website Navigational Information
Trade Technologies uses commonly-used information-gathering tools, such as cookies to collect information as you navigate the Company’s Websites (“Website Navigational Information”). As described more fully below, we use these cookies or similar technologies to analyze trends, administer Websites and Services, track users’ movements around our Websites and Services, deliver targeted marketing information and gather demographic information about our user base as a whole. This section describes the types of Website Navigational Information used on the Company’s Websites and Services, and how this information may be used.
Log Files, IP Addresses, URLs and Other Data
As is true of most Websites, we gather certain information automatically to analyze trends in the aggregate and administer our Websites and Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use the Company’s Websites and Services, we automatically receive the URL of the website from which you came and the website to which you go when you leave our Website. This information is used to analyze overall trends, to help us improve our Websites and Services, to track and aggregate non-personal information, and to provide the Websites and Services. For example, the Company uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Websites. The Company also collects IP addresses from Customers when they log into the Services as part of the Company’s “Identity Confirmation” and “IP Range Restrictions” security features.
Do Not Track
Currently, various browsers — including Internet Explorer, Firefox, and Safari — offer a “do not track” or “DNT” option that relies on a technology known as a DNT header, which sends a signal to Websites’ visited by the user about the user's browser DNT preference setting. Trade Technologies does not currently commit to responding to browsers' DNT signals with respect to the Company's Websites, in part, because no common industry standard for DNT has been adopted by industry groups, technology companies or regulators, including no consistent standard of interpreting user intent. The Company takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
7. Public Forums and Customer Testimonials
The Company may provide bulletin boards, blogs, or chat rooms on the Company’s Websites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums and may be used to send you unsolicited messages. The Company is not responsible for the personal information you choose to submit in these forums.
The Company may post a list of Customers and testimonials on the Company’s Websites that contain information such as Customer names and titles. The Company obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.
8. Sharing of Personal Data Collected
Unless otherwise described in this Privacy Statement, the Company does not share, sell, rent, or trade Personal Data with third parties.
Trade Technologies Affiliates
The Company may share Personal Data with affiliates of Trade Technologies in order to provide our Services. For example, the Company may need to share Personal Data with other companies within the Trade Technologies corporate family in order to provide the Services or for customer support, marketing, technical operations and account management purposes.
In certain cases, Trade Technologies contracts with other companies to provide certain Services such as training events. If you register for a training event or otherwise utilize our Services provided by such companies, we may share Personal Data collected in connection with the delivery of such Services with our partner(s). Trade Technologies meets all legal standards in this respect and where necessary has concluded data processing agreements that provide the level of Personal Data protection which is granted by applicable law.
The Company does not share Personal Data about Attendees with business partners unless: (1) you specifically opt in to such sharing via an event registration form; or (2) you attend a Company event. If you do not wish for your information to be shared in this manner, you may choose not to opt in via event registration forms. If you choose to share your Personal Data with business partners in the manners described above, your information will be subject to the business partners’ respective privacy statements.
Website Navigational Information
Section 6 of this Privacy Statement, Website Navigational Information, specifically addresses the information we collect through cookies and web beacons, and how you can control cookies through your Web browsers. We do not share this information with any third parties.
The Company uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf.
The Company reserves the right to use or disclose Personal Data provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.
9. International Transfer of Information Collected
Trade Technologies is a global company headquartered in the United States and where the laws of your country allow us to do so, you authorize us to transfer, disclose, store and use your Personal Data in the United States and any other country where we operate or engage service providers to assist us with the Service consistent with this Notice.
For citizens of the EEA: Please be aware that the laws of the USA and other countries outside of the EEA may not protect your Personal Data to the same level as the laws of the EEA, or give you the same rights that you would have in the EEA (including right relating to access to personal data by law enforcement or national security/intelligence agencies). But when we transfer your Personal Data outside of the EEA, if the receiving country’s data protection laws do not offer the same level of protection as the laws of the EEA, we place contractual obligations (e.g. the EU Model Clauses) on the recipients of your personal data to ensure that your personal data is adequately protected.
This Privacy Statement shall apply even if the Company transfers Personal Data about Customers or Attendees to other countries.
10. Communications Preferences
Trade Technologies offers Visitors, Customers, and Attendees who provide contact information a means to choose how the Company uses the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of the Company’s marketing emails. Additionally, you may unsubscribe here or by contacting us using the information in the “Contacting Us" section below.
11. Correcting and Updating your Information
The Company may retain your Personal Data for a period of time consistent with the original purpose of collection. For instance, we may retain your Personal Data during the time in which you or your employer have an account to use our Websites or Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for the Company to pursue our legitimate business interests in accordance with applicable laws, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
12. Rights of EEA Citizens
As a citizen of the EEA, you have the following rights:
The right to information
(Art. 13 GDPR)
This is your right to be informed whether and to what extent we process your personal data.
The right of access
(Art. 15 GDPR)
This is your right to get a confirmation as to whether or not we process your personal data, and only if we (still) do, request access to your data.
The right to rectification
(Art. 16 GDPR)
This is your right to request correction of your personal data, or completion, in case that the data we process is incorrect or incomplete.
The right to deletion
(Art. 17 GDPR)
This is your right to request deletion of your personal data. Yet, an immediate deletion may not be possible, if the retention of your personal data is still required to meet legal or regulatory obligations.
The right to restrict the processing
(Art. 18 GDPR)
This is your right to request a restriction of the processing of your personal data under certain conditions:
If you have reasons to doubt the accuracy of your personal data, you may request that its processing is restricted while we verify its accuracy.
If the processing of your personal data is considered unlawful, but you do not request the deletion of your personal data.
If we no longer need the data for the purposes of its processing, but you need it for the establishment, exercise or defense of legal claims.
If you object to the processing of your personal data based on our legitimate interests under Art. 6(1) (f) GDPR, or where the processing is based on Art. 6(1) (e) GDPR.
The right to data portability
(Art. 20 GDPR)
Where the processing takes place on the basis of your consent or contract, and is carried out by automated means, you have the right to request that we provide your personal data to you in a machine-readable format.
The right to object to the processing
(Art. 21 GDPR)
You have the right to object to the processing of your personal data in certain situations.
Rights in relation to automated decision making and profiling
(Art. 22 GDPR)
You have the right to object to decisions based exclusively on the automated processing of your personal data.
The right to withdraw your consent
If your personal data is processed on the basis of your consent (Art. 6 (1) (a) or Art. 9 (2) (a) GDPR), you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
You also have the right to file a complaint with a competent supervisory authority. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Union are available at ec.europa.eu.
If you have registered as a user with the Company, you may generally update your user settings and profile by logging into the applicable Website or Service with your username and password and editing your settings or profile. To update your billing information, discontinue your account, and/or request return or deletion of Your Data associated with your account, you may also contact your account representative or the customer service team for the applicable Service. For other requests to access, correct, modify or delete Your Data, please review the “Contacting Us” section above. Requests to access, change, or delete your information will be addressed within one month[KL1] . If you are an employee of a Trade Technologies customer, you may also wish to contact your employer’s system administrator for assistance in correcting or updating your information.
Trade Technologies uses robust security measures to protect all Customer and other confidential data entrusted to us, including Personal Data. Please contact us if you have questions or concerns about our data security measures or policies.
14. Changes to this Privacy Statement
Trade Technologies reserves the right to change this Privacy Statement. The Company will provide notification of the material changes to this Privacy Statement through the Company’s Websites at least thirty (30) business days prior to the change taking effect.
Copyright © 2020 Trade Technologies, Inc. All Rights Reserved.