PRIVACY NOTICE

Last Modified: October 10, 2022

Technology Recovery Group Ltd. (“TRG,” “us,” “we,” or “our”) processes information about you as described in this Privacy Notice (“Notice”). This Notice contains details about how TRG collects, uses, stores, and shares personal information and how you can exercise your privacy rights.

PRIVACY NOTICE CONTENTS

1. Applicability
2. Changes to This Notice
3. What Types of Personal Information We Collect
4. How We Collect Personal Information
5. Lawful Bases for Processing Personal Information
6. How We Use Your Personal Information
7. Security and Retention
8. With Whom We Share Your Personal Information
9. Limitation of Liability for Third-Party Sites and External Links
10. Cookies and Advertising Technologies
11. International Transfers of Your Personal Information
12. EEA Privacy Rights
13. California Residents Rights
14. Children's Privacy
15. Your Privacy Preferences and Our Contact Information

1. APPLICABILITY

This Notice applies to Personal Information (defined hereinafter) about individuals with whom we interact in the conduct of our business, such as individuals who visit our website or who are employed by or associated with one of our vendors, customers, or other business partners.

2. CHANGES TO THIS NOTICE

TRG may update this notice from time to time at our sole discretion. All changes are effective as soon as they are posted and your continued use of this website and interactions with TRG are subject to the most current version of this Notice.

3. WHAT TYPES OF PERSONAL INFORMATION WE COLLECT

Personal Information refers to any information relating to an identifiable natural person. Personal Information also includes information that does not reveal your specific identity or does not directly relate to an individual, but could, when combined with other data, link back to you (collectively, “Personal Information”). Personal Information does not include information that has be de‐identified with all identifying information removed and is not capable of being re‐identified to you.
The Personal Information that TRG currently collects includes:

• Identifiers, such as your name, company, job title/specialty, organization type, email address, mailing address, shipping address, billing address, phone number, fax number, banking, credit card and other payment‐related information that you provide to us and Internet Protocol (IP) address.
• Internet or other electronic network activity information, such as information about your website use (including clickstream information including which TRG page was visited and how much time was spent on the page and search history), information regarding your interactions with TRG (including online, by mobile application, and through advertisements), network routing information (where you came from), equipment information (browser type or device type), date and time, general geolocation information, aggregate usage, and performance data.
• Interaction history such as invoice history, details of your online inquiries, product orders, or conversations you may have with TRG sales representatives, details of your purchased products/services, and inferences drawn from any of the personal information we collect to create a profile about you reflecting your preferences.

TRG will not seek to collect Sensitive Personal Data from you, which includes but is not limited to racial or ethnic origin, physical or mental health, and religious beliefs.
TRG does not collect all of the above types of information in all cases. TRG  may also collect information in an anonymized or aggregate format (in a way that does not identify you).

4. HOW WE COLLECT PERSONAL INFORMATION

We collect Personal Information both directly and indirectly in several ways, including:

• Information you provide to us directly, such as in person, in an email or letter, in a phone call, or on a web form.
• Information automatically collected through the use of technologies such as cookies, web beacons, electronic communication protocols, or widgets, buttons, and tools.
• Publicly available information and information from third parties, such as commercially available sources, vendors and third‐party services providers. For example, by providing your information to, and participating in, a trade show or similar event, your Personal Information may be provided to us indirectly through the organizers of the event.
• Through online product orders system. By using our online product portal hosted by VARStreet, you may be eligible to purchase our products, for which you have an existing Master Sales Agreement in place with TRG. All such sales shall be governed by and subject to the terms and conditions of the Master Sales Agreement, any applicable terms and conditions and privacy policy of VARStreet or such other host vendor as TRG may use, and the applicable TRG Merchant Policy. In many cases, when purchasing our products you may be asked to provide contact information, such as your name, address, email address, phone number, and credit/debit card information.

We may combine information that we receive from the different sources described above; for example, we may create a profile based on Personal Information provided directly from you and input information regarding your interaction history with sales representatives into that profile.

5. LAWFUL BASES FOR PROCESSING PERSONAL INFORMATION

Our lawful basis for processing the Personal Information described in this Notice depends on the type of Personal Information and the specific context in which we collect it. We will normally process your Personal Information from you only (1) where you have provided your consent for us to do so, (2) where we need the Personal Information to perform a contract with you or provide services or goods to you that you have requested, or (3) where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to process your Personal Information.

You are able to remove your consent at any time. You can do this by contacting us using the information in the “Your Privacy Preferences and Our Contact Information” section below.

6. HOW WE USE YOUR PERSONAL INFORMATION

We may use your Personal Information in several ways, including:

• To enable interactions between you and TRG, such as to facilitate your purchase or sale of goods and services and generally to conduct our business, to support you and the organization with which you are associated in your interactions with TRG, to provide requested product or service information, to communicate with you about past, future, or existing orders, and to respond to your requests and inquiries.
• To enable online product purchases. Whether you purchase products through our online product portal or directly through TRG, we will use the personal information you provide only to process that order. We do not share this information with outside parties except to the extent necessary to complete that order.
• For our own internal business purposes, such as to help us tailor our services to you and other customers, improve or evaluate the use, performance, and safety of programs and technologies related to interactions with TRG such as our website, to evaluate and improve the quality of your user experience, to design new products and services, to conduct data analysis and testing, and to maintain proper business and other relevant records.
• For legal, safety, or security reasons, such as to comply with legal requirements, to protect the safety, property, and rights of TRG, those who interact with TRG, and others, including in emergency situations, to enforce or apply our terms of use and other agreements, and to detect, prevent, and respond to security incidents or other malicious, deceptive, fraudulent, or illegal activity.
• For marketing, such as providing information on new and existing TRG products and services, to enhance our content, and to send you marketing communications regarding our products and services.
• For any other purpose that is compatible with the foregoing or for which you provide consent.

You may opt‐out of receiving certain communications, such as marketing communications from TRG, at any time by using the information in the “Your Privacy Preferences and Our Contact Information” section below.

7. SECURITY AND RETENTION

TRG uses appropriate technical and organizational measures to protect your Personal Information that we process. The measures we use are designed to provide a level of security appropriate to the risk associated with processing your Personal Information. Unfortunately, no transmission or storage system can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security and we do not warrant that your Personal Information will not be subject to unauthorized uses or disclosures.
TRG will retain your Personal Information for as long as needed to provide you products or services, as needed for the purposes outlined in this Notice or at the time of collection, as necessary to comply with our legal obligations (for example, to comply with opt‐out requests), resolve disputes and enforce our agreements, or to the extent permitted by law.

8. WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

TRG does not sell, trade, or rent your Personal Information. We may share your Personal Information with other persons or entities, including the categories of recipients described below:

• Affiliates and subsidiaries: Corporate parents, affiliates, subsidiaries, business units, and other companies that share common ownership with TRG;
• Third‐Party Service Providers: Third‐Party service providers working on behalf of TRG to facilitate an interaction with TRG that you request or to support our relationship with you and the organization with which you are associated, including but not limited to, IT systems and service providers, website hosts, data analysis, marketing providers, shipping/order fulfillment, email distribution, CRM, promotions management, and payment processing. We provide these companies with only the information they need to perform their services and work with them to ensure that your privacy is respected and protected;
• For legal, security, and safety purposes: Law enforcement or other government agencies to comply with law or legal requirements, to enforce or apply our terms of use and other agreements, and to protect our rights and the property or safety of TRG;
• In connection with a transaction: In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition or all or any portion of our business, assets, or stock (including in connection with any bankruptcy or other similar proceeding); and
• Your employer or coworkers: If you interact with TRG in connection with your employment, we may share Personal Information with other individuals designated by your organization.

9. LIMITATION OF LIABILITY FOR THIRD-PARTY SITES AND EXTERNAL LINKS

This Notice does not address, and we are not responsible for, privacy, information, or other practices of any third parties, including any third party operating any website or service to which TRG’s website may link, including those embedded in third‐party advertisements or sponsor information. We strongly suggest that you review the privacy notices, statements, or policies of those organizations to understand how your Personal Information may be processed by those organizations.

10. COOKIES AND ADVERTISING TECHNOLOGIES

Like many companies, TRG uses “cookies” and other similar technologies to recognize or track visitors to a website such as web beacons, tracking pixels, clear gifs, as well as third‐party advertising networks and website analytics such as Google Analytics, Google AdWords, and others which are subject to change from time to time at our sole discretion without notice (collectively, “Cookies”).

What Are Cookies?

A Cookie is a small text or graphic file which is placed on your device if your web browser permits containing a unique identifier.

Cookies set by the website owner (in this case, TRG) are called "first‐party cookies". Cookies set by parties other than the website owner are called "third‐party cookies." Third‐party cookies enable third‐ party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third‐party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.

Cookies on our website are either “session cookies”, meaning that they are automatically erased from your computer or device when you close your browser, or “persistent cookies” that stay in one of your browser’s subfolders after you close your browser. Some cookies are required for technical reasons, called "essential"