Last modified: May 16, 2023
Our processing of personal information, such as your name, address, e-mail address, or telephone number, will be undertaken consistent with the requirements of applicable privacy laws, including, but not limited to, the California Consumer Privacy Act (“CCPA”), the California Privacy Rights Act (“CPRA”), the EU General Data Protection Regulation (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”).
A. INFORMATION WE COLLECT AND PROCESS
TrellisWare collects both personal and non-personal information. In general, personal information is information that could be used—directly or indirectly—to identify a natural person or which could be reasonably linked to a natural person or their household. Except to the extent required by applicable law, the term “personal information” as used in this Policy does not include information publicly available from government records or information you choose to post on public websites, demographic information (zip code, etc.), data automatically collected about you when you access or use the TrellisWare Services (with the exception of unique device identifiers and, in some jurisdictions, IP addresses), or information which has been de-identified (personally identifiable elements are removed or extracted such that they cannot be used to identify or reasonably be linked to a natural person or their household). The information that we collect from you depends on how you interact with the TrellisWare Services. For any type of interaction, we strive to only collect the personal information that we need. When you purchase products or services, contact us, sign up for a Customer Support Center account or request support services, browse the TrellisWare Services, or otherwise interact with the TrellisWare Services, we may collect a variety of information, including:
- Contact information: Data such as name, email address, postal address, telephone phone number, or other contact information.
- Payment and transaction information: Data about your billing address, signature, and method of payment, such as bank details, credit, debit, or other payment card information.
- Device and commercial information: Data about products or services purchased, obtained, or considered by you, other purchasing or consuming histories or tendencies, and data from which your device could be identified, such as device serial numbers or software versions.
- Account information: Customer Support Center account details, including email addresses, devices, account status, physical location, citizenship/residency status, and employer.
- Internet or similar network activity: Internet Protocol address, browsing history, search history, information on your interaction with the TrellisWare Services, application, or advertisement, device identifier, operating system, and data regarding network connected hardware. See “Information we get automatically from your use of the TrellisWare Services” in this Section (A) for more details on the types of information we automatically collect when you use the TrellisWare Services.
- Protected classification characteristics under California or federal law: Age, race, color, ancestry, national origin, citizenship, veteran or military status.
- Professional or employment-related information: Address, telephone number, citizenship/residency status, physical characteristics or description, passport number, driver’s license or state identification card number, job title, the company or organization you work for, employment records, information related to security clearances, employment history, current or past job history or performance evaluations, other details you may provide if you apply to work for us, medical information, data relating to the health status of an individual, health insurance and policy numbers, certifications and registrations, education records such as institutions attended, grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
- Other information you provide to us: Details such as the content of your communications with TrellisWare, including interactions with customer support personnel and contacts through social media channels.
You are not required to provide personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests that you may have. In certain circumstances, we may need to cancel a product or service you have with us, and if this is the case, we will notify you at the time.
We obtain the categories of information listed above from the following categories of sources:
- Information voluntarily submitted by you. Users of the TrellisWare Services may provide us with information directly.
- Information you post. Any comments or information that you post on public websites is publicly available and may be viewed, collected, and used by others, including TrellisWare.
- Information obtained from service providers. Service providers who provide services on our behalf such as those used to monitor activity on our services, provide analysis and analytics, maintain databases, administer and monitor emails and marketing, and provide IT security and consulting services may provide us with information.
- Information we get automatically from your use of the TrellisWare Services. When you use the TrellisWare Services, we may collect certain information by automated means, using technologies such as cookies, tracking pixels, web server logs, web beacons, or other similar technologies or services. We may also use third-party web-analytics services such as Google Analytics to collect information. The information we may automatically collect includes:
- Unique device identifiers, call state, network access, storage and battery information;
- Cookies, data identifying your operating system, web browser and version, and web beacons and tags;
- Information about your use of the TrellisWare Services, including referring URLs, pages you viewed, the amount of time you spend using the TrellisWare Services, the number of times you return, and other TrellisWare Services usage data; and
- Information about your physical location gathered through various technologies, such as your IP address and the country that you download materials from.
Our cookies and other analytics technologies do not collect personal information and we do not combine the general information collected through cookies with other personal information provided to us to tell us who you are.
B. HOW WE USE THE INFORMATION WE COLLECT AND THE LEGAL BASES FOR OUR USE
We do not engage in automated decision making. TrellisWare uses personal information to process your transactions, to provide services and products to you, to communicate with you, for security purposes, to comply with the law and regulations, and as otherwise necessary for our legitimate interests. We may also use personal information for other purposes with your consent. We only use your personal information when we have a valid legal basis to do so.
We may use the personal information we collect about you, as well as store such information in our systems, for the following purposes:
- To Process Your Transactions. We use your information to fulfill and process your requests for our products and services, including helping you to complete transactions, process payments, and other customer service purposes, to perform and administer customer contracts, to enable you to use certain features of our products and services, such as enabling you to utilize software updates and upgrades, to facilitate shipping of product (including communication with freight forwarders, customs brokers, and shippers), and for billing/collections purposes. Use of this information is necessary for the performance of the contract between you and TrellisWare.
- To Provide Customer Service and Manage Business Relationships. We use your information to provide business and technical support for our products and to maintain relationships with customers, business partners, and suppliers. Our use of this information is necessary for the performance of the contract between you and TrellisWare as well as for our legitimate interests, specifically, internal administrative purposes, customer/product support, and maintenance of customer business relationships.
- To Communicate with You. We use your information to respond to communications, contact you about your transactions, account, or products/services, market our products and services, and provide other relevant information or request feedback. We may use your personal information to send important notices, such as communications about purchases, products, or policy changes. From time to time, we may communicate with you about, and administer your participation in, special events, programs, offers, surveys and market research. Our use of this information is necessary for the performance of the contract between you and TrellisWare as well as for our legitimate interests, specifically, customer/product support, and maintenance of customer business relationships.
- To Maintain our Products, Improve our Offerings and Operate our Business. We use your information to operate, evaluate, manage, and improve our business, including developing new products and services, enhancing and improving our products and services, analyzing our products, services and communications, and performing accounting, auditing and other internal functions. Our use of this information is necessary for our legitimate interests, specifically, internal administrative purposes, and customer/product support.
- For Security Purposes. We use personal information to protect against, identify, and prevent cybersecurity and other security events, espionage, fraud and other unlawful activity, claims and other liabilities, and comply with and enforce applicable legal requirements, relevant industry standards and our policies. Our use of this information is necessary for our legitimate interests, namely the interest of preventing fraud, crimes, and/or unlawful behaviors and protecting company assets and facilities.
- To Comply with the Law. We screen personal and shipping information against denied parties’ lists, systems, and other regulation-based lists so that we can ensure compliance with import/export controls and regulations. We also use information to comply with other applicable laws—for example, to satisfy tax or reporting obligations, to comply with lawful governmental and law enforcement requests. Our use of this information is necessary for our legitimate interests, namely the interest of preventing fraud, crimes, export violations, and/or unlawful behaviors.
- To Process Employment Applications and Intermediary Requests. We use your information to process your employment applications, including by assessing qualifications, verifying information, and conducting reference or other employment-related checks. We also use your information to conduct due diligence for entities and individuals who desire to act as a sales representative, distributor or consultant for TrellisWare. Our use of this information is necessary for our legitimate interests, specifically human resources purposes and in the interest of preventing fraud, crimes, and/or unlawful behaviors.
- For IT System Management. We store your personal information in our active directory systems for server, user, domain, or access management. Our use of this information is for our legitimate interests, namely for the purposes of ensuring network and information security.
- To Operate Our Websites. We use your information to help us track and understand how visitors use our websites, to present the websites and its content to you, ensure network and information security, and monitor and improve the performance and user experience of our websites. Our use of this information is for our legitimate interests, namely for the purposes of operating our website and ensuring network and information security.
- To the Extent that you Provide your Consent. In the event that we ask you for consent to use your information for a purpose not described above, we will use the collected information for the purposes provided to you at the time of our request. Where we rely on consent to collect and maintain your data, you can withdraw your consent to such activities at any time.
TrellisWare reserves the right to collect, use, share and transfer non-personal information to the fullest extent not prohibited by applicable law or inconsistent with this Policy or representations made by us in writing at the time of collection. TrellisWare is not responsible for the privacy of any information that you choose to post on public websites or for the accuracy of any information contained in those postings and cannot control how others use your shared/posted information. To the extent that any non-personal data is combined by or on behalf of us with personal information we collect directly from you, TrellisWare will treat such information as personal information under this Policy.
If you have questions about the legal basis for our collection or use, please contact us as indicated in the “How to Contact Us” section below.
Do Not Track Signals (DNT) and Universal Opt-Out Preference Signals
Most browsers will allow you to limit tracking or to block cookies by enabling a Do Not Track (DNT) or similar feature that signals to web services that a visitor does not want to have their online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including TrellisWare, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.
New standards are being developed for a Universal Opt-Out Mechanism, such as the Global Privacy Control (GPC), which allow users with GPC-enabled browsers and devices to send a signal that will communicate the user’s request to opt-out of sales of their personal information and to opt-out of certain sharing of their personal information. The CPRA and other laws allow for the acceptance of Opt-Out Preference Signals such as the GPC, as an option for users to transmit an Opt-Out of selling/sharing personal information. If we detect and recognize such a signal from your device or browser, we will honor it.
C. SHARING OF INFORMATION
TrellisWare may disclose the personal information that we collect from and about you for the following business and commercial purposes: (1) to our employees, parent company or affiliates, or third-party vendors, agents, service providers, or contractors, if the disclosure is made for a business purpose, including enabling them to perform a professional, information technology, security, or technical support function for us; (2) to respond to legal process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, where necessary or appropriate given issues of public importance, or otherwise as required by law; (3) as otherwise described to you or directed by you at the point of collection; or (4) with your consent, to third-parties who may sell you ancillary or competing services. TrellisWare neither sells your personal information without your consent nor shares your personal information with third-parties for their direct marketing purposes. We may also disclose information about you where we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of reorganization, merger, or sale.
Collection and Use of Sensitive Information
We have collected the following categories of sensitive personal information from consumers within the last twelve months:
- Government identifiers
- Complete account credentials
- Racial or ethnic origin
- Religious or philosophical beliefs
- Union membership
- Mail, email, or text message contents
- Unique identifying biometric information
- Health, sex life, or sexual orientation
We do not use or disclose sensitive personal information for purposes other than those specified in the CCPA/CPRA.
D. PROTECTION OF PERSONAL INFORMATION & OUR COMPANYWIDE COMMITMENT TO YOUR PRIVACY
TrellisWare treats your information and privacy with the utmost importance. We have put in place appropriate physical, administrative, and technical measures to protect the personal information we collect from and about users of the TrellisWare Services against accidental loss, misuse, unauthorized access, disclosure, alteration, and destruction, including storage of your information on secure servers located within our facilities or hosted in secure cloud-based environments. We have procedures in place to deal with any suspected breach and will notify you and any applicable regulator of a breach where we are legally required to do so. While we seek to ensure the integrity and security of our network and systems, we cannot guarantee the security of the information you transmit to us. We encourage you to take precautions to protect your personal data when you are on the Internet.
E. TRANSFER, STORAGE, AND RETENTION OF PERSONAL INFORMATION
The information that we collect from users of the TrellisWare Services is primarily stored on servers in the United States but may also be transferred and stored on servers in various non-U.S. locations. By using the TrellisWare Services or providing any personal information to us, you fully understand and consent to TrellisWare transferring such information to the U.S., to any country in which TrellisWare and its service providers maintain systems or facilities, and to other countries globally. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, you acknowledge that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, consistent with our legal obligations governing the transfer of such data.
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal information, we consider the nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable laws and requirements.
F. THIRD-PARTY SITES, CONTENT AND SERVICES
G. RIGHTS AND CHOICES REGARDING YOUR PERSONAL INFORMATION
To the extent provided by the law of your jurisdiction, you may have the right to (a) access certain personal information we maintain about you; (b) exercise your right to data portability; (c) request that we update, correct, amend, erase, or restrict your personal information; (d) request that we not share your personal information with third parties for ancillary or competing services; and/or (e) object at any time to the processing of your personal information on legitimate grounds relating to your particular situation.
We will comply with such requests to the extent required by the applicable law of your jurisdiction but may not accommodate a request if we believe that the change would violate any law or legal requirement or cause the information to be correct—for example, if you ask us to delete your transaction data and TrellisWare is legally obligated to keep a record of that transaction to comply with the law. We may also decline to grant a request where doing so would undermine our legitimate use of data for security purposes. We may take steps to verify your identity or may request specific information from you to help us confirm your identity and to assess whether the legal right applies in the circumstances. This information may include name, contact information, and information related to your transaction or relationship with TrellisWare, but the specific information requested may differ depending on the circumstances of your request. This is also a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may apply a charge, to the extent permitted by applicable law before we provide you with a copy of any of your personal information we maintain. You may, depending on your location, have a right to file a complaint with a government regulator if you are not satisfied with our response.
If you wish to exercise any of these rights where they apply, please contact us as indicated in the “How to Contact Us” section below to discuss your options.
California Privacy Rights
In addition to the rights set out in this Policy, California law also provides for some additional rights for California consumers, which are summarized in this section.
We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine the Light law”) with third parties for their direct marketing purposes absent your consent. To opt-out of future sharing with third parties for their direct marking purposes, contact us using the contact information in Section K below. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us using one of the methods set forth in Section K below. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.
California residents have certain rights under the California Consumer Privacy Act (CCPA). For purposes of compliance with the CCPA, we make the following disclosures. TrellisWare provides notice of our privacy practices in this Policy. This Policy includes what personal information is collected, the source of the personal information, and the purposes of use, as well as whether TrellisWare discloses that personal information and if so, the categories of third parties to whom it is disclosed. In summary:
- We collect the following categories of personal information: Identifiers (such as name and address), online identifiers (such as device identifier), internet or other electronic network activity information (such as browsing history), payment, transaction, and other commercial information (such as products or services inquired about and bank details), online account information, characteristics of protected classifications under California or federal law, professional or employment-related information, other information you provide to us, and inferences drawn from the preceding categories of personal information.
- We collect personal information from the following categories of sources: directly from you, from information you post online, directly and indirectly from activity on the TrellisWare Services, and from service providers.
- We collect personal information about you for one or more of the following business purposes: to process your transactions, to provide customer service and manage business relationships, to communicate with you, to maintain our products, improve our offerings and operate our business, for security purposes, to comply with the law, to process employment applications and intermediary requests, for information technology system management, to operate our websites, and for other reasons to the extent that you provide your consent.
- We disclose the following categories of personal information for a business purpose: Identifiers, online identifiers, internet or other electronic network activity information, commercial information, and professional or employment-related information. The business purposes for sharing such information are set forth in Section C of this Policy.
We do not sell your personal information.
California residents also may exercise the following rights under the California Consumer Privacy Act (CCPA), to the extent required by the CCPA and subject to certain exceptions and verification:
- Right to Know/Access: The right to request certain information about our collection and use of personal information about you as described below:
- The specific pieces of your personal information collected.
- The categories of your personal information collected.
- The categories of sources from whom your personal information is collected.
- The purpose for collecting your personal information.
- The categories of third parties with whom we have shared your personal information.
- Right to Delete: The right to request that we delete certain personal information we have about you.
- Freedom from Discrimination: You have the right to be free from unlawful discrimination for exercising any of your privacy rights.
- Right to Correct: You have the right to request that we correct inaccurate personal information regarding the information you provide us.
- Right to Restrict the Use of Sensitive Personal Information: You have the right to restrict the use of your sensitive personal information.
- Right to Access Information on Automated Decision-Making: You have the right to access information collected through automated decision-making. Additionally, you can opt-out of our use of automated decision-making related to your personal information.
California consumers may exercise their rights either directly or through an authorized agent. To exercise your rights, contact us using one of the methods in Section K below. We will not discriminate against you, such as by denying you access to our products or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your rights under the CCPA. However, if you refuse to provide your personal information or ask us to delete it, and that personal information is necessary for us to provide you with goods or services or otherwise complete a transaction, maintain security in compliance with applicable laws, regulations, or our standards, or does not allow us to comply with our legal requirements, we may not be able to complete your transaction. If you would like to understand how a request may affect a particular transaction, please contact us at email@example.com.
Upon receipt of your request, we will ask you for information that we consider necessary to verify your identity for security and to prevent fraud. This information may include name, contact information, and information related to your transaction or relationship with TrellisWare, but the specific information requested may differ depending on the circumstances of your request for your security and to protect privacy rights. If you choose to use an authorized agent, that authorized agent must follow the same authentication procedures that are required if you exercise your rights without using an agent. TrellisWare will verify requests made through authorized agents to help ensure the safety of your account and to comply with our policies and procedures. We will respond to requests within 45 days of our receipt of your request. If we require additional time to make a determination or implement a decision, we will notify you at that time.
H. Canada, European Union and United Kingdom Privacy Rights
If our processing of your personal information is subject to GDPR, UKGDPR, and/or PIPEDA, and unless subject to an exemption, you may have the following rights with respect to your personal information:
- To request a copy of the personal information we hold about you and where possible, to transmit that data directly to another data controller.
- To request we correct any personal information about you.
- To request your personal information be erased when no longer necessary for us to retain such data;
- To withdraw your consent to the processing of your personal information.
- To request a copy of the personal information we hold about you.
- Where there is a dispute in relation to the accuracy or processing of your personal information, to request a restriction be placed on further processing.
- To object to the processing of personal information (where applicable).
- To lodge a complaint with a data supervisory authority.
We will need to verify your identity to process any requests described in this Section and may deny your request if we are unable to verify your identity. Government or other identification may be required.
If you are a resident of the European Economic Area (“EEA”), when we process your personal information, we will only do so in the following situations:
- We need to use your information to perform our responsibilities under our agreement with you.
- We have a legitimate interest in processing your personal information. For example, we may process your personal information to send you marketing communications, to communicate with you about the TrellisWare Services, and to provide and improve the TrellisWare Services.
- We have your consent to do so.
If your personal data is subject to GDPR or UK GDPR, we will transfer personal data from the EEA to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.
I. OUR COMMITMENT TO CHILDREN’S PRIVACY
Protecting the privacy of children is important to us. We do not direct the TrellisWare Services to, nor do we knowingly solicit or collect any personal information from, children under the age of thirteen. If you believe that we might have any information from or about a child under thirteen, please contact us using the contact information below.
J. CHANGES TO THIS POLICY
TrellisWare may amend this Policy from time to time. When we do, we will post the change(s) on the TrellisWare Services. In some cases, we may provide you with additional notice (such as an email notification). Please check our websites frequently for any updates or changes to this Policy.
K. HOW TO CONTACT US
If you have any questions that you would like to ask about this Policy or about our handling of the information collected by the TrellisWare Services, or if you’d like to make a request relating to the section entitled Rights and Choices Regarding Your Personal Information, please email TrellisWare’s privacy office (Legal Dept.) at firstname.lastname@example.org or give us a call at 1-858-753-1600. Requests sent via email must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code in the body of the email.