- Introduction and General Concepts
We respect and uphold individual rights to privacy and the protection of personal information. We know how important it is to protect your personal information and want to make every customer experience safe and secure. In keeping with that goal, we have developed this Policy to explain our practices for the collection, use, and disclosure of your personal information. We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.
- Personal Information
For the purposes of this Policy, “personal information” means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number, social insurance number, sex, income and family status. Personal information does not include information that would enable an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. We will only collect, use or disclose personal information in accordance with this Policy, or in accordance with laws applicable to the collection, use and disclosure of your personal information by us (“Applicable Privacy Laws”).
- Non-Personal Information
On the other hand, “non-personal information” is any type of information other than personal information, and is excluded from this Policy. For example, non-personal information would include business information, or information that enables an individual to be contacted at a place of business, for example an employee’s name, position or title, business telephone number, or business address. Non-personal information also includes information that is anonymous or not about an identifiable information, such as web browsing information (such as the domain used to access the Website, or the type and version of device, browser or operating system being used to access the Service), or aggregate information that anonymizes the underlying data (like the number of visitors, what pages users visit, average time spent on the Website or on various parts of the Service). We will collect, use or disclose non-personal information in accordance with our ordinary business practices, but always in accordance with any applicable laws. This Policy, however, only covers our collection, use and disclosure of personal information.
- Information about Minors
This site is not intended for minors and no person under the age of majority may register for a User Account. We do not knowingly collect personal information about any person under the age of majority (usually the age of 18 or 19, but it varies in different jurisdictions) including any person under the age of 13, and no such person, nor any parent or guardian as it relates to such person, should submit their personal information to us for any reason. Please do not submit personal information about minors to us, whether through the Website, the Service or otherwise.
- Privacy Officer
We have appointed a Privacy Officer who is responsible for our compliance with this Policy. Information on how to contact the Privacy Officer can be found below.
- Collection and Use of Personal Information
As indicated above, we collect two types of information through our Service: personal information and non-personal information. The types of information we collect about you will depend on the nature of your interaction with us or the Service.
- Information we collect from you
We may collect the following personal information from you:
- contact information such as name, email address, mailing address, phone number;
- billing information such as credit card number, and billing address;
- unique identifiers such as user name, account number, password;
- professional information including licences, qualifications, training, certificates, insurance, and tax related information;
- user content generated by you, such as audio, video, text and images as provided by you on the Website, which may contain personal information as provided by you;
- preferences information such as comment history and marketing preferences; and
- any information that you voluntarily enter, including personal information, into any postings, comments, reviews, or forums with Trust Hero or third parties from whom we collect reviews and comments.
- Information we automatically collect
We also automatically gather information about your computer such as your IP address, browser type, referring/exit pages, operating system, as well as which aspects of our performance metric indicators available with our technology or our licensees’ products you prefer using. Some of this may be personal information, but in typical cases it is non-personal information. Specific examples follow:
- IP, etc.—When using our Website, we may collect the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access our Website, the Internet address of the website from which you linked directly to our Website, the operating system you are using, the sections of our Website you visit, the Website pages read and images viewed, and the content you download from the Website. This information is used for Website and system administration purposes, and to improve the Website.
- Cookies—We use “cookies”, a technology that installs a small amount of information on a user’s computer to permit the Website to recognize future visits using that computer. Cookies enhance the convenience and use of the Website. For example, the information provided through cookies is used to recognize you as a previous user of the Website, to offer personalized content and information for your use, to track your activity at the Website, to respond to your needs, and to otherwise facilitate your Website experience. You may choose to decline cookies if your browser permits, but doing so may affect your use of the Website and your ability to access certain features of the Website or engage in transactions through the Website.
- Geo-Location Information—When you use the Service through a mobile device, we may track or collect your geo-location information on a real time basis only. We may also use this real-time geo-location information to address support, technical, or business issues that may arise in the course of your use of the Service. If you do not consent to the tracking of your geo-location, you may still be able to use some features of the Service, but it is intended to be used with geo-location information. You may at any time withdraw your consent as permitted through the Service, or you can turn the geo-location tracking off at the device level as permitted by the manufacturer of your device. In our experience, your mobile device informs you when geo-location is tracked by displaying the GPS arrow icon.
- Use of Personal Information
We may use your personal information, in combination with your non-personal information, for a variety of business purposes, for example to:
- fulfill your request for Trust Hero;
- send you a Services request confirmation, if applicable;
- respond to Member or Convert Customer service requests;
- administer your User Account;
- send newsletters or campaigns to you or others;
- carry out contests or promotions;
- send you marketing communications;
- compile your comments and reviews as provided on the Website or through the Services;
- respond to your questions and concerns;
- improve our Services and marketing efforts;
- conduct research and analysis;
- to enforce our Terms of Service;
- display content based upon your interests;
- for distribution to our payment processor for the provision of payment services;
- for distribution to Third Party Providers for the provision of services requested in relation to your Convert Services, including for call forwarding or recording services;
- facilitate your transactions with other Users or Members, as applicable; and
- for other purposes as described in this Policy.
- Your Consent
We will collect, use, or disclose your personal information only with your knowledge and consent, except where required or permitted by Applicable Privacy Laws. When you choose to provide us with your personal information you consent to the use of your personal information as identified in this Policy and as may be further identified at the time of collection.
- Express Consent
Sometimes you will be asked to give your express consent to our collection, use or disclosure of personal information – for example, by being asked to check a box to indicate your consent to receive marketing communications in compliance with Canada’s anti-spam laws.
- Implied Consent
Other times, you may provide your implied consent to our collection, use or disclosure of personal information when we can reasonably conclude that you have given consent by some action you have taken or an action you have decided not to take. Generally, this occurs where the purpose for the use of your personal information would be reasonably apparent to you – for example, using your name and email in a review invite sent to your customer.
- Withdrawing Your Consent
You may notify us at any time that you wish to withdraw or change your consent to our use and disclosure or your personal information. We will accommodate your request subject to legal and contractual restrictions. The most common way of indicating this withdrawal of consent is (i) by changing your privacy preferences to the extent such functionality is made available through the Service, or (ii) deleting your account with the Service and stopping use of the Service. In other situations, you may be able to opt out of the use of your personal information. For example, if you have “opted in” or subscribed to one of our mailing lists, we will always provide you the opportunity to “opt out” or unsubscribe. For example, if you receive emails from us, we will provide a link in the email which you can use to unsubscribe from that mailing list, or you may contact us at [email protected]
You may also choose not to provide us with your personal information. However, if you make this choice we may not be able to provide you with the Service, or information that you have requested. For example, we require your email address in order to verify your User Account, which is necessary so that notifications may be sent to you electronically.
- Information Obtained from Third Parties
If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us and in accordance with this Policy and such policy under which that information was collected. For example, we may obtain information provided by you on social media sites including Facebook, LinkedIn, and Twitter as well as from review sites including Google, Yelp, and CitySearch. We may also collect information provided by you from customer intelligence platforms; for example, ClearBit. This list is only an example of third party sites from which me may obtain information and is subject to change at any time.
- Disclosure and Sharing of Your Information
We will share your personal information with third parties only in the ways that are described in this Policy. We will not sell your personal information to third parties, however the use of our Service necessarily requires some sharing or disclosure of your personal information. Some of these activities may result in personal information collected by us being stored or processed in the United States or elsewhere outside of Canada and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with the USA PATRIOT Act and other applicable laws of the United States or elsewhere.
We may provide your personal information to Members in the course of providing our Services to them. By providing personal information through the Services or to a Member you acknowledge and agree that we and the Members may share and use such information, including for a commercial purpose. For example, we may provide your personal information to Members for the purposes of the Members analytics, and in the case of User Content, for their marketing purposes.
- Third Party Processors
We may provide your personal information to companies that provide services to help us with the Service such as web hosting providers, payment processors, product shipping providers, fulfilment agencies, or customer service agencies (“Third Party Processors”). These Third Party Processors are authorized to use your personal information only as necessary to provide these services to us, and in a manner consistent with this Policy. We have selected Third Party Processors who will only use your information in compliance with this Policy, but they may have their own specific policies regarding the collection, use and personal information. We will use commercially reasonable efforts to identify such Third Party Processors when we are collecting your personal information, as well as providing links to the relevant privacy policies that may apply.
Here are some examples of the Third Party Processors we use as part of the Service:
- Our Service is physically hosted by Digital Ocean, Amazon Web Services, and Google Cloud Platform, reputable hosting platforms with industry standard security and practices.
- We do not directly process payments through our Service. We use Stripe and their privacy terms are available here: https://stripe.com/ca/privacy. We only ourselves collect and store limited parts of that information to provide a record of your transaction and to prevent fraud (such as a part of a credit card number, or a part of your billing address).
- We gather information about how you and others use our Service. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our site is used. We may also use unique codes, web beacons or single-pixel gif tags to compile tracking information reports regarding Service user demographics, Service traffic patterns, and other aggregated Website or Service statistics, both on the Website and in our electronic communications in order to determine which materials and links have been used by recipients. We may then provide these reports to Members, advertisers and others.
- We do not directly provide call forwarding or call recording through our Services. We use Twilio and their privacy terms are available here: https://www.twilio.com/legal/privacy. We only ourselves collect and store limited parts of that information to complete your request for such services and to prevent fraud (such as a part of a credit card number, or a part of your billing address).
- You can log in to our Service using sign-in services such as Google. These services will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form. Services like Google give you the option to post information about your activities on this Service to your profile page to share with others within your network.
- You can connect a variety of 3rd party applications to Trust Hero, such as Facebook, Zapier, and other software. Depending on the application you connect, certain personal information may be shared for authenticating your connection or for achieving the purpose of the 3rd party integration.
- Further Disclosures
We may also disclose your personal information (i) as required by law such as to comply with a subpoena, or similar legal process, (ii) 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, or (iii) to any other third party with your prior consent to do so.
- Third Party Links
Our Service may contain links to other websites or Internet resources which are provided solely for your convenience and information. When you click on one of those links you are contacting another website or Internet resource. We have no responsibility or liability for, or control over, those other websites or Internet resources or their collection, use and disclosure of your personal information. We encourage you to read the privacy policies of those other websites to learn how they collect and use your personal information.
- Public Forums
We may from time to time provide publicly accessible blogs or community forums through the Service. We will use your personal data as provided through those services to administrate and provide you with these public services, and you will have primary control over what information you make publicly available. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them.
- Security of Personal Information
- General Security Practices
The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. We employ physical, administrative, contractual and technological safeguards to protect personal information, and insist that our service providers do the same. We insist that our personnel, and those of our providers, only access and use personal information in order to properly perform those duties, and even then only to the strict extent necessary to perform them.
- Online Security
When you enter sensitive information (such as credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). SSL encrypts information entered on our site before it is sent over the Internet, and we use SSL in an industry-recognized standard manner to encrypt our Internet transmissions to and from you. In addition, to the extent we do store your personal information, some of it may be stored it in encrypted form, and it is unencrypted in memory by our Service when and as needed. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure, and so you should always exercise caution when disclosing sensitive information over the Internet.
If you have any questions about security on our Website, you can contact us at [email protected]
- Requests for Access to and Correction of Personal Information
Applicable Privacy Laws allow, to varying degrees, individuals the right to access and/or request the correction of errors or omissions in his or her personal information that is in our custody or under our control. Our Privacy Officer will assist you with such an access request. This includes:
- identification of personal information under our custody or control;
- information about how personal information under our control may be or has been used by us; and
- the names of any individuals and organizations to which the individual’s personal information has been disclosed.
We will respond to requests within the time allowed by Applicable Privacy Laws and will make every effort to respond as accurately and completely as possible. Any corrections made to personal information will be promptly sent to any organization it was disclosed to.
In certain exceptional circumstances, we may not be able to provide access to certain personal information it holds about an individual. If access cannot be provided, we will notify the individual making the request within 30 days, in writing, of the reasons for the refusal.
- CASL Policy
We are committed to compliance with the law known as Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication sent by us to outside parties is protected by a range of business procedures, processes and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message we send (a “CEM”), which is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting this Policy, and to provide transparency about our compliance, we have undertaken various initiatives in order to ensure we are compliant with CASL in various respects:
- Consent—We do not send CEMs without your consent. This consent typically must be “express” (or expressly acknowledged by you), but in certain circumstances consent can be “implied” and in others, messages are specifically exempt from consent requirements. We have modified or adopted our sign-up, registration and consent forms in order to ensure that the express consent obtained from you is in compliance with CASL. When we are collecting your electronic contact information, you will know what purposes we want to use it for.
- Content—We have adopted processes to ensure that our CEMs contain the prescribed content of CASL. On any CEM from us (usually in the footer), we will clearly:
- Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
- Provide you contact information where you can readily contact us; and
- Set out a clear, working unsubscribe mechanism (or preference centre) that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
- Clarity—We have ensured that each constituent element of a CEM (including its header, its content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole, so that you always know what you are clicking on.
If you have received a CEM from us, and you believe that you should not have or you do not wish to receive them (even if we are allowed to send them), we will endeavour to respect your inbox preferences. Without limiting our legal rights or obligations, we try to ensure that our messages all contain useful identity information and unsubscribe or preferences link in our messages—if you check the CEM itself, you will find clear instructions on how to stop receiving CEMs from us or manage your mail preferences. When you unsubscribe, it should happen very quickly – but as required by CASL we will make sure it occurs within 10 business days. If you have any questions or concerns about our unsubscribe methods, you may contact us at the address indicated below.
- Removal of Your Information
We keep your information only as long as we need it for legitimate business purposes and to meet any legal requirements. Personal information used to make a decision that directly affects an individual will be kept for at least one year after such a decision. We have retention standards that meet these parameters. We destroy your information when it is no longer needed or required to be kept, or we remove your personally identifiable information to render it anonymous.
- Contact Information
You can direct any questions or concerns regarding our compliance with this Policy to our Privacy Officer by writing or emailing at:
Adlerstr. 79, 40211 Duesseldorf, Germany
Email: [email protected]
If you are not satisfied with our Privacy Officer’s response to their question or concern you may be able to make a complaint under Applicable Privacy Laws. Our Privacy Officer can provide you with the contact information to make such a complaint.