TRG 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

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

What Do We Use Cookies For?

We use first‐party and third‐party cookies for several reasons. Cookies help analyze web traffic and are used to improve your user experience by recognizing your browser as a previous visitor and saving any preference that may have been set on previous visits to the website, eliminating the need for repeated entry of the same information. Cookies also help us customize the content and advertisements provided to you on TRG’s website and on other websites, to improve site performance, and to measure the success of email marketing campaigns.

To do this, the following types of information may be collected through the use of Cookies: IP address used to connect your computer to the Internet; computer and connection information such as browser type and version, operating system, and platform; your activities on our website, including what you view/search for, as well as the URL you come from and go to next (whether this URL is on our site or not); and cookie number.

What third party cookies does TRG use?

Some cookies, web beacons and other tracking and storage technologies that we use are from third party companies (third party cookies), such as LinkedIn, Facebook, YouTube, Google Analytics, Triblio, JotForm and SoPro to provide us with web analytics and intelligence about our sites which may also be used to provide measurement services and target ads. 

Digital Marketing Service Providers
We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of
personal information. 

• LinkedIn - https://www.linkedin.com/legal/privacy-policy
• Facebook - https://www.facebook.com/about/privacy/previous
• YouTube - https://www.youtube.com/t/terms
• Google - https://policies.google.com/privacy
• Triblio - https://triblio.com/privacy-policy/
• JotForm - https://www.jotform.com/privacy/
• SoPro - https://sopro.io/legal/#privacy-policy

Our appointed data processors include:
(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can
contact Sopro and view their privacy policy here: https://sopro.io/legal/#privacy-policy. Sopro are
registered with the ICO Reg: ZA346877 their Data Protection Officer can be
emailed at: dpo@sopro.io.

How does TRG use web beacons? 

We may also use web beacons (including conversion pixels) or other technologies for similar purposes as above and we may include these on our sites, in marketing e‐mail messages or our newsletter, affiliated websites, to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but they may work in conjunction with cookies to monitor website activity. The information provided below about cookies also applies to web beacons and similar technologies. Conversion pixels are small codes located on a particular web page which are triggered when someone visits a page resulting in an increase in the conversion count.

How Can You Manage Your Cookies?

You can choose to accept or decline Cookies. You can adjust your cookie settings through our Cookie Consent Manager. If you want to block future cookies being placed on your device you can use our cookie consent manager. If you want to remove existing cookies from your device, you can do this using your browser options. Most web browsers automatically accept Cookies unless you modify your setting to decline them. If you would prefer not to accept cookies, most browsers will allow you to:

1. Change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it
2. To disable existing cookies
3. To set your browser to automatically reject any cookies
4. You can also manage cookies for our Site by visiting our Cookie Management Tool. This tool provides a listing of all the cookies we utilize and allows you However, please be aware that if you disable or reject cookies, some features and services may not work properly. In addition, the advertisements we provide when you visit us may not be as relevant to you or tailored to your interests.

You can manage your receipt of targeted advertising by visiting these sites:

• in the EU, https://www.youronlinechoices.eu/  
• in the U.S. and other regions, https://youradchoices.com/control

11. International Transfers of Your Personal Information

TRG processes Personal Information as a Controller and a Processor as defined in the General Data Protection Regulation. When you provide Personal Information directly to TRG, through our website, through interactions with TRG, through our services, or otherwise, you understand and agree that your Personal Information may be transmitted across state and national boundaries to the United States where TRG is headquartered and any of the countries and locations in which TRG and our third‐ party service providers maintain web servers or offices. By using our Site or Services and providing us with your information directly you are consenting to the collection, use, and storage or your personal information outside of your country of residence. If you do not agree to such transfers please discontinue the use of this Site or our Services.
As such, your Personal Information may be transmitted to and processed in countries other than the country in which you are a resident. These countries may have data protection and privacy laws that are different to the laws of your country and may not be as comprehensive or protective as those in your country of residence; however, our processing of your Personal Information will at all times continue to be governed by this Notice.

12. EAA Privacy Rights

For Personal Information of European Economic Area (“EEA”) residents or where EEA data protection laws apply, with certain exceptions and limitations, you may exercise the following rights regarding your Personal Information:

• Right to Access: You can ask us for a copy of your Personal Information.
• Change or Correction: You have the right to ask us to change information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
• Right to Portability: You have the right to ask us to transfer the information you gave us to another organization, or to you, in certain circumstances.
• Object to, or Limit or Restrict, Processing: You can ask us to stop using all or some of your Personal Information (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if it is inaccurate or unlawfully held).
• Deletion: You can ask us to erase or delete all or some of your Personal Information in certain circumstances (e.g., if it is no longer necessary to provide products or services to you).
• We will only collect and process Personal Information about you where we have one or more of the lawful bases described in this Notice. Where we rely on your consent to process Personal Information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you, unless additional time is needed, in which case we will let you know.
You may exercise your rights by submitting a request using the information in the “Your Privacy Preferences and Our Contact Information” section below.

13. California Resident Rights 

Under the California Consumer Privacy Act (“CCPA”), we are required to notify certain California residents about our collection, use, and disclosure of their personal information (whether collected through this website or otherwise).  In this section of our Privacy Notice, and in accordance with the CCPA, “personal information” includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
 
In this section of our Privacy Notice, and in accordance with the CCPA, “personal information” includes any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including the categories identified in the table below to the extent they identify, relate to, describe, are capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.
 
With respect to such personal information, we may collect and utilize personal information directly or through our affiliated companies or Vendors for the following business or commercial purposes (as those terms are defined in applicable law):

• providing the Services (e.g., account servicing and maintenance, customer service, analytics, and communication about the Services);
• for our operational purposes or those of our affiliated companies or Vendors;
• auditing consumer interactions on our site;
• detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• bug detection and error reporting;
• customizing content that we or our Vendors display in relation to the Services;
• improving our existing Services and developing new services (e.g., by conducting research to develop new products or features);
• other uses that advance our commercial or economic interests, such as communicating with you about relevant products and services available to you from third party partners; or
• other uses about which we may notify you from time to time.

Categories of Personal Information that We Collect, Disclose, and Sell

Below please find the categories of personal information about California residents and information regarding our collection, disclosure, and sale to our affiliated companies, Vendors, third parties, or service providers for business and commercial purposes:

Categories of Personal Information	Do we collect?	Do we disclose for business purpose?	Do we sell?
NAME, CONTACT INFORMATION AND IDENTIFIERS: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Yes	Yes	No
CUSTOMER RECORDS: Paper and electronic customer records containing personal information, such as name, signature, social security number, Signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, , employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.	Yes	Yes	No
PROTECTED CLASSIFICATIONS: Characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, citizenship status, and genetic information.	No	No	No
PURCHASE HISTORY AND TENDENCIES: Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes	Yes	No
BIOMETRIC INFORMATION: physiological, biological or behavioral characteristics that can be used alone or in combination with each other to establish individual identity, including DNA, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.	No	No	No
USAGE DATA: Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a resident’s interaction with an internet website, application, or advertisement.	Yes	Yes	No
GEOLOCATION DATA: Precise geographic location information about a particular individual or device	Yes	Yes	No
AUDIO/VISUAL: Audio, electronic, visual, thermal, olfactory, or similar information.	No	No	No
EMPLOYMENT HISTORY: Professional or employment-related information.	Yes	No	No
EDUCATION INFORMATION: Information that is not publicly available personally identifiable information as defined in the federal Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).	No	No	No
PROFILES AND INFERENCES: Inferences drawn from any of the information identified above to create a profile about a resident reflecting the resident’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No	No	No

Using Personal Information Subject to CCPA

In addition to the permissible uses described elsewhere in this Notice, we will only use your personal information to the extent permitted by law. Most commonly, we will use your personal information in the following circumstances:

• Where you have provided consent to the use;
• Where we need to use it to perform the contract we are about to enter into or have entered into with you;
• Where we need to comply with a legal or regulatory obligation;
• Where it is in our legitimate interests, including our commercial interests. When using personal information in these circumstances, we consider and balance potential negative impacts on you and your rights to the extent required by applicable law before using your personal information.

California Residents’ Rights

California law grants certain rights to California residents and imposes restrictions on particular business practices as summarized below. California residents have the right to request that we disclose to you what personal information we collect, use, disclose, and sell about you.

Do-Not-Sell

California residents have the right to opt-out of any sale of your personal information.  We do not sell personal information about California residents.

Verifiable Requests for Copy, Deletion and Right to Know

Subject to certain exceptions, California residents have the right to make the following requests, at no charge, up to twice every 12 months (please see ‘Submitting Requests’ below for instructions about how to exercise your rights):

Deletion

The right to request deletion of your personal information that we have collected about you, subject to certain exemptions, and to have such personal information deleted, except where otherwise limited by law;

Copy

The right to request a copy of the specific pieces of personal information that we have collected about you in the prior 12 months;

Right to Know (Collection)

Where we have collected your personal information, you have the right to request that we disclose to you certain information about how we have handled your personal information in the prior 12 months, including the categories of personal information collected, categories of sources of personal information, business and/or commercial purposes for collecting personal information, and the categories of third parties/with whom we have disclosed or shared your personal information. We do not collect your information for sale to third parties.

14. Children's Privacy

TRG’s interactions are not directed at, marketed to, or intended for individuals under the age of 13 years. TRG does not knowingly collect any information, including Personal Information, from individuals under 13 years of age. If a parent or guardian believes that their child has provided us with his or her Personal Information without their consent, please contact us using the information in the “Your Privacy Preferences and Our Contact Information” section below.

15. Your Privacy Preferences and Our Contact Information

TRG enables you to opt‐out of marketing communications. If you no longer wish to receive marketing communications from TRG you can opt‐out at any time by emailing dsr@trgsolutions.com with “unsubscribe” in the subject line.

To exercise your rights regarding your personal information, or if you have questions regarding this Privacy Notice or our privacy practices please contact us by emailing dsr@trgsolutions.com. 

Please note that when you submit a request, we will take steps to attempt to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. As part of our verification process, we may ask you to submit additional information, use identity verification services to assist us, or, if you have set up an account on our website, we may ask you to sign in to your account as part of our identity verification process. Please understand that, depending on the type of request you submit, to protect the privacy and security of your personal information, we will only complete your request when we are satisfied that we have verified your identity to a reasonably degree of certainty.

Contact details for the DPO (Data Protection Officer)
Joseph Yanoska, CIO/DPO
Email Address: dataprotection@truwestco.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in certain parts of the EEA, you may have the right to lodge a complaint with the competent supervisory authority.