TRACEgifts Personal Data Notice

Your Personal Data Notice

in connection with your use of TRACEgifts

Types of personal information and why we process it

TRACE International, Inc. (“TRACE”) processes your personal information in connection with the provision of the Service (as defined below) and operation of the TRACEgifts web site (the “Site”). Such information may include: your name, title, company name, business email, phone number, any other personal information you may choose to post, store or transmit using the Site or Service.

The “Service” includes (a) the Site, and (b) all software, data, text, images, sounds, video, and content made available through the Site or services (collectively referred to as the “Content”).

In addition, when you access the Site or use tools and services made available to you through the Site, TRACE or its authorized service providers may process your login credentials, IP address, website cookies, internal unique identifier, and other session details to authenticate your account, determine your account permissions, perform market research, implement Site functionality, handle system errors, maintain the security of the Site, preserve your user settings, address your requests for technical support, and for other similar purposes.

Where we process it

Personal data may be processed by TRACE for the purposes specified above in the following locations:

  • Ireland (the location of our servers, and the primary location of EU data processing);
  • United Kingdom (the location of our back-up servers);
  • United States (the location of TRACE’s headquarters);

Additionally, depending on your location, your personal data may be processed by the following TRACE Subprocessors, only as necessary for the performance of the Service:

Subprocessor Location Nature of services to TRACE
Microsoft Corporation (Microsoft Azure) Ireland, with a backup in the United Kingdom Cloud data hosting
DC Web Troupe, LLC, d/b/a Modern Signal United States Software development and IT support
Docebo NA, Inc. Global; primarily United States Compliance training / Learning Management System (LMS) solutions
TRACE Consultant(s) Currently located in United States, Philippines, Italy, and United Kingdom. TRACE contracts with various independent contractors for the provision of marketing, continuing education support, and customer service, to enable us to better serve customers in their local language and time zones. Consultants based in the Philippines are firewalled from accessing any EU/EEA/UK personal data.

Any transfers of your personal data between countries will be done strictly in compliance with applicable law. Any transfer of personal data from the European Union and the European Economic Area (EU/EEA) or the United Kingdom (UK) to the United States is based either on specific consent of data subjects or the standard contractual clauses executed by TRACE with relevant entities located in the EU, EEA, or UK, as the case may be.

How long we keep it

We keep your personal data for up to thirty days from the moment your account with the Site is cancelled. We may keep your basic personal information (such as your name, position, contact information, signature) for a longer period of time if you are a signatory of a contract or an agreement with TRACE, in accordance with our data retention schedule.

What are your rights?

At any time, you may:

  • request to see your personal data that we have;
  • request to correct or delete your personal data if you believe it is incorrect;
  • object to TRACE’s processing of your personal data or the transfer of your data to TRACE; or
  • bring a complaint on how we have handled your personal data.

In any such instance, you may contact TRACE’s Data Protection Officer by email at [email protected]. In addition, if you reside in the European Union, you can contact TRACE’s EU Representative at [email protected]. If contacted, TRACE may seek additional information from you to make sure that the personal data we may possess belongs to you. Once verified, we will evaluate your request and provide you with a response.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you may file a complaint with the Data Protection Commissioner at [email protected] or the supervisory authority located in your jurisdiction.

Last Updated: 24 August 2023

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